Section 122.3

Administrative Policy

27 November 1992 T.I. 920738 (September 1993 Access Letter, p. 421, ¶C117-203)

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15 January 1990 Memorandum (June 1990 Access Letter, ¶1272)

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Articles

Novek, "Employment Tax Credit: Sector Specific Tax Relief for Canadian Residents Working Overseas", Taxation of Executive Compensation and Retirement, September 1993, p. 808.

Subsection 122.3(1) - Overseas employment tax credit

Cases

Meredith v. Canada (Attorney General), 2002 DTC 7190, 2002 FCA 258

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Corporate/Separate Personality shareholder and corporation were separate 117

Rooke v. Canada (Attorney General), 2002 DTC 6442, 2002 FCA 393 (FCA)

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Timmins v. The Queen, 99 DTC 5494 (FCA)

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Words and Phrases
carried on business
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business N.B. government had a servicing undertaking, i.e., a business 161

Timmins v. The Queen, 96 DTC 6378 (FCTD)

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Tax Topics - General Concepts - Evidence 39

See Also

Legge v. The Queen, 2011 DTC 1302 [at 1699], 2011 TCC 413

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MacIsaac v. The Queen, 2010 TCC 436

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Humber v. The Queen, 2010 DTC 1170 [at 3371], 2010 TCC 253 (Informal Procedure)

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Thompson Trailbreakers Snowmobile Club Inc. v. The Queen, 2005 DTC 1807, 2005 TCC 269 (Informal Procedure)

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Purves v. The Queen, 2005 DTC 684, 2005 TCC 290 (Informal Procedure)

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Adams v. The Queen, 2005 DTC 636, 2005 TCC 237 (Informal Procedure)

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Administrative Policy

25 September 2013 External T.I. 2013-0497011E5 F - OETC - Qualifying period

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18 July 2013 External T.I. 2013-0493081E5 - Definition of "Outside Canada" - Water Boundaries

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 255 143

18 April 1995 Memorandum 950099 (C.T.O. "Overseas Employment Tax Credit Computers")

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25 October 1994 T.I. 941323 (C.T.O. "Overseas Employment Tax Credit")

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31 January 1994 External T.I. 5-932951 -

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23 December 1993 Internal T.I. 7-933595 -

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93 CPTJ - Q.8

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93 CPTJ - Q.7

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93 CPTJ - Q.6

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18 June 1993 T.I. (Tax Window, No. 32, p. 15, ¶2611)

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18 June 1993 T.I. (Tax Window, No. 32, p. 5, ¶2596)

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Articles

Pooja Samtani, "Employees on Foreign Ground: The Overseas Employment Tax Credit", Taxation of Executive Compensation and Retirement, Vol. 17, No. 8, April 2006, p. 663.

John Mill, "Canada's Overseas Employment Tax Credit", Tax Notes International, Vol. 35 No. 11, 13 September 2004, p. 995.

Paragraph 122.3(1)(b)

Administrative Policy

2 November 2011 External T.I. 2011-0413641E5 F - CIEE

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5 November 2010 External T.I. 2010-0383871E5 F - Crédit d'impôt pour emploi à l'étranger

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Words and Phrases
substantially all

Subparagraph 122.3(1)(b)(i)

Clause 122.3(1)(b)(i)(A)

See Also

Humber v. The Queen, 2010 DTC 1170 [at 3371], 2010 TCC 253 (Informal Procedure)

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Clause 122.3(1)(b)(i)(B)

Administrative Policy

9 November 2016 External T.I. 2014-0537121E5 F - Overseas employment tax credit

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Words and Phrases
construction

Paragraph 122.3(1)(d)

Administrative Policy

10 December 2012 External T.I. 2011-0429721E5 F - OETC - Employee stock options benefits

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) s. 7(1)(a) benefit generally relates to duties performed in the grant year 173

Subsection 122.3(1.01) - Specified amount

Administrative Policy

30 January 2015 External T.I. 2014-0521751E5 - overseas employment tax credit

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Transitional Provisions "extension" of contract one day after it expired could result in a new contract 136

Subsection 122.3(1.1)

Paragraph 122.2(1.1)(c)

See Also

Gillespsie v. The Queen, 2009 DTC 295, 2009 TCC 26

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