Section 126

Table of Contents

Section 126
Subsection 126(1) - Foreign tax deduction
Cases(2)
See Also(4)
Administrative Policy(32)
Articles(3)
Subsection 126(2) - Idem [Authorized foreign bank]
Cases(1)
See Also(3)
Administrative Policy(3)
Articles(4)
Subsection 126(2.1) - Amount determined for purposes of para. (2)(b)
Administrative Policy(3)
Subsection 126(2.2) - Non-resident’s foreign tax deduction
Articles(1)
Subsection 126(2.21) - Former resident — deduction
Administrative Policy(1)
Subsection 126(3) - Employees of international organizations
Administrative Policy(2)
Subsection 126(4.1) - No economic profit
Administrative Policy(1)
Articles(1)
Subsection 126(4.2) - Short-term securities acquisitions
Administrative Policy(1)
Subsection 126(4.5)
Articles(1)
Subsection 126(6) - Rules of construction
Paragraph 126(6)(c)
Administrative Policy(1)
Subsection 126(7) - Definitions
Business-Income Tax
Cases(1)
See Also(1)
Administrative Policy(17)
Non-Business-Income Tax
Cases(2)
See Also(17)
Administrative Policy(25)
Articles(2)

Subsection 126(1) - Foreign tax deduction

Cases

Interprovincial Pipe Line Company v. Minister of National Revenue, 68 DTC 5093, [1968] CTC 156, [1968] S.C.R. 498

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(3) 57

Interprovincial Pipe Lane Co. v. Minister of National Revenue, 59 DTC 1229, [1959] CTC 339, [1959] S.C.R. 763

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See Also

Arsove v. The Queen, 2016 TCC 283 (Informal Procedure)

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Tax Topics - Treaties - Articles of Treaties - Article 24 application of Art. 24 of Canada-U.S. Treaty to IRA distribution to U.S. citizen 206

White v. The Queen, 2003 DTC 1170, 2003 TCC 668 (Informal Procedure)

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Shere v. MNR, 89 DTC 201 (TCC)

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Curtis Brown, Ltd. v. Jarvis (1929), 14 TC 744 (K.B.D.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property 78

Administrative Policy

13 June 2017 STEP Roundtable, Q.4

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 94 - Subsection 94(16) election of US-citizen/Cdn-resident beneficiary of grantor trust so as to generate FTC 250
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(5) - Paragraph 108(5)(a) income from factually U.S.-resident but s. 94(3) trust was U.S.-sourced 112

13 April 2017 External T.I. 2015-0601781E5 - U.S. tax paid in respect of an LLC's income

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Tax Topics - Treaties - Articles of Treaties - Article 24 Canada's denial of foreign tax credits re undistributed LLC income is consistent with Art. 24 of Canada-US Treaty 345

12 July 2016 External T.I. 2014-0560361E5 - Cdn beneficiary of US living trust

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) question of fact whether a U.S. revocable living trust is an excluded trust 128
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) potential application to U.S. revocable living trust 178

8 December 2016 Internal T.I. 2016-0634231I7 - Pension received from the European Union

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Words and Phrases
government

29 November 2016 CTF Roundtable Q. 12, 2016-0669851C6 - Support for US FTC Claims

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May 2016 Alberta CPA Roundtable, Q.10

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3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 124
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax LLC tax paid by Cdn member not re business 163
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) only income was taxable capital gains 131
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) s. 20(14) deduction for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 418
Tax Topics - Treaties - Articles of Treaties - Article 24 Treaty sourcing rule does not trench on domestic FTC 208

2015 Ruling 2015-0572541R3 - Foreign Tax Credit on Transfer of 401(k) to RRSP

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax additional 10% tax on withdrawal from 401(k) plan, as income tax 111
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j) 21

23 July 2015 External T.I. 2014-0546571E5 - Foreign Tax Credit

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30 October 2014 External T.I. 2013-0500491E5 - Pension from XXXXXXXXXX

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Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(i) EU Treaty does not engage s. 110(1)(f)(i) exemption 92
Tax Topics - Income Tax Act - Section 126 - Subsection 126(3) pension income not employment income 70

23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax foreign tax not a "tax" if no refund sought 190
Tax Topics - Treaties - Articles of Treaties - Article 24 s. 40(3) gain had Cdn source 224

11 September 2014 External T.I. 2013-0495091E5 - Reimbursement of employee's foreign tax

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) taxable benefit from foreign tax reimbursement 145

10 June 2013 STEP Roundtable, 2013-0480311C6 - 2013 STEP CRA Roundtable - Question 5

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28 May 2013 Internal T.I. 2013-0476381I7 - Deemed Resident Trusts & Foreign Tax Credit

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) no s. 20(12) deduction available where only a capital gain 148
Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(b) 283

S5-F2-C1 - Foreign Tax Credit

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20 February 2003 External T.I. 2002-014360 -

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Tax Topics - Treaties - Articles of Treaties - Article 24 37

5 April 2001 External T.I. 2000-004361 -

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14 December 2000 External T.I. 2000-002957 -

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8 September 1998 T.I. 982008

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26 January 1996 T.I. 951618 (C.T.O. "Meaning of 'for the Year' in Section 126")

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21 April 1995 T.I. 942293 (C.T.O. "Foreign Tax Credit (HAA7988-1)")

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1994 December Tax Executives Institute Roundtable, 5-943052 -

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1 September 1994 Memorandum 933143 (C.T.O. "Meaning of Proportion in 126(1)(b)")

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17 May 1993 T.I. (Tax Window, No. 31, p. 12, ¶2525)

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5 March 1993 Memorandum (Tax Window, No. 30, p. 17, ¶2471)

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20 January 1993 T.I. 921629 (November 1993 Access Letter, p. 506, ¶C117-209)

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17 November 1992 T.I. 923120 (September 1993 Access Letter, p. 413, ¶C56-250)

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IT-270R2 "Foreign Tax Credit"

IT-395R2 "Foreign Tax Credit - Foreign-Source Capital Gains and Losses"

IT-194 "Foreign Tax Credit - Part-Time Residents"

IT-506 "Foreign Income Taxes as a Deduction from Income"

IT-183 "Foreign-Tax Credit - Member of a Partnership"

Articles

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

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Jack Bernstein, "Canada-US Tax Traps for LLCs", Canadian Tax Highlights, Volume 22, Number 2, February 2014, p. 11

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Kenneth Snider, "The Foreign Tax Credit Rules", 2001 Conference Report, c. 14.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(4.1) 0

Subsection 126(2) - Idem [Authorized foreign bank]

Cases

The Queen v. Bank of Nova Scotia, 81 DTC 5115, [1981] CTC 162 (FCA)

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Words and Phrases
payable

See Also

4145356 Canada Limited v. The Queen, 2011 DTC 1171 [at 937], 2011 TCC 220

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Words and Phrases
paid

C.I.R. v. HK-TVB International Ltd., [1992] BTC 524 (PC)

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Leonard Reeves Inc. v. MNR, 91 DTC 425 (TCC)

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Administrative Policy

S5-F2-C1 - Foreign Tax Credit

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11 January 2001 Internal T.I. 2000-0001017 -

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Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) place of contract not primary determinant 267

IT-520 "Unused Foreign Tax Credits - Carryforward and Carryback"

Articles

Kyle B. Lamothe, "The Missing Provincial Tax Credit for Foreign Business-Income Taxhttps://www.ctf.ca/ctfweb/FR/Newsletters/Canadian_Tax_Focus/2016/2/160213.aspx", Canadian Tax Focus, Vol. 6, Number 2, May 2016, p. 10

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Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

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Kenneth Snider, Michael Platt, "The Ontario Foreign Tax Credit Regime after Harmonization", International Tax, No. 64, CCH, June 2012, p. 12: Discusses double tax problem that arises inter alia where a Canadian corporation subject to Ontario tax has foreign-source business income but no foreign permananet establishment.

Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3.

Locations of other summaries Wordcount
Tax Topics - Treaties - Articles of Treaties - Article 24 0

Subsection 126(2.1) - Amount determined for purposes of para. (2)(b)

Administrative Policy

11 January 2001 Internal T.I. 2000-000101 -

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8 July 1992 T.I. 921814

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88 CPTJ - Q.5

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Subsection 126(2.2) - Non-resident’s foreign tax deduction

Articles

Steve Suarez, "Tax Planning for Departure from Canada", 1991 Canadian Tax Journal 7, p. 1.

Subsection 126(2.21) - Former resident — deduction

Administrative Policy

6 February 2011 External T.I. 2011-0427211E5 - Recovery of Departure tax

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Subsection 126(3) - Employees of international organizations

Administrative Policy

30 October 2014 External T.I. 2013-0500491E5 - Pension from XXXXXXXXXX

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(i) EU Treaty does not engage s. 110(1)(f)(i) exemption 92
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) EU withholding does not qualify as state tax 116

10 February 1994 Memorandum 933403 (C.T.O. "Employees of International Organizations")

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Subsection 126(4.1) - No economic profit

Administrative Policy

S5-F2-C1 - Foreign Tax Credit

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Articles

Kenneth Snider, "The Foreign Tax Credit Rules", 2001 Conference Report, c. 14.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) 0

Subsection 126(4.2) - Short-term securities acquisitions

Administrative Policy

Manjit Singh and Andrew Spiro, "The Canadian Treatment of Foreign Taxes," draft version of paper for CTF 2014 Conference Report.

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Subsection 126(4.5)

Articles

Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50

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Subsection 126(6) - Rules of construction

Paragraph 126(6)(c)

Administrative Policy

5 November 2012 Internal T.I. 2012-0462151I7 - Foreign Tax Credits

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Subsection 126(7) - Definitions

Business-Income Tax

Cases

Canadian Wireless Telecommunications Association v. Nanaimo (City), 2012 DTC 5131 [at 7250], 2012 BCSC 1017

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See Also

Clevite Development Ltd. v. MNR, 61 DTC 1093 (Ex. Ct.)

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Administrative Policy

24 November 2013 CTF Roundtable, 2013-0508171C6 - Income or profits tax

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5 September 2013 External T.I. 2011-0431031E5 - Guatemala's taxes

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S5-F2-C1 - Foreign Tax Credit

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11 May 2012 External T.I. 2011-0428791E5 - Foreign Tax Credit

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18 July 2002 Internal T.I. 2002-0148217 -

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24 October 2000 External T.I. 1999-001511 -

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1999 Ruling 992920

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8 November 1999 T.I. 991413

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Income Tax Technical News, No. 8, 3 September 1996 "Treatment of United States Unitary State Taxes".

4 September 1996 T.I. 961290 (C.T.O. "Creditability of U.S. Branch Profits Tax")

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12 August 1996 T.I. 962086

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10 July 1995 T.I. 943044 (C.T.O. Pennsylvania Franchise Tax")

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93 C.M.TC- Q. 5

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18 May 1993 T.I. (Tax Window, No. 31, p. 13, ¶2527)

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6 April 1993 TI 9301815

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28 January 1993 T.I. (Tax Window, No. 28, p. 9, ¶2403)

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23 November 1992 T.I. 922181 (September 1993 Access Letter, p. 417, ¶C96-044)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 37

Non-Business-Income Tax

Cases

Yates v. The Queen, 2001 DTC 761 (TCC) (Informal Procedure)

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Words and Phrases
tax

The Queen v. Hoffman, 85 DTC 5508, [1985] 2 CTC 347 (FCTD)

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See Also

Nadeau v. The Queen, 2007 DTC 1670, 2004 TCC 433 (Informal Procedure)

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Meyer v. The Queen, 2004 DTC 2393, 2004 TCC 199 (Informal Procedure)

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Words and Phrases
tax

Yates v. GCA International Ltd., [1991] BTC 107 (Ch. D.)

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Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) petroleum consulting income rose only partly in field 91

Newfoundland and Labrador Corporation Ltd. et al. v. Attorney General of Newfoundland, 138 DLR (3d) 577, [1982] 2 S.C.R. 260

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Inland Steel Co. v. U.S., 677 F. 2d 72, 230 Ct. Cl. 314, 82-1 U.S.TC P9301 (1982)

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Lai v. MNR, 80 DTC 1044 (T.R.B.)

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Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545

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Bank of America National Trust and Savings Association v. U.S., 72-1 U.S.TC 84456, 198 Ct. Cl. 263, 459 F. 2d 513, cert. denied 490 U.S. 949 (1972)

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Allstate Insurance Co. v. U.S., 419 F. 2d 409 (Ct. Cl. 1969)

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Words and Phrases
excise tax

Quemont Mining Corp. Ltd. v. MNR, 66 DTC 5376, [1966] CTC 570 (Ex. Ct.), aff'd 70 DTC 6046 (SCC)

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Words and Phrases
profits

Seley v. MNR, 62 DTC 565, 30 Tax A.B.C. 243

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Abbot Laboratories International Co. v. U.S., 160 F. Supp. 321 (D. Ct. 1958), aff'd 267 F. 2d 940 (C.A. 1959)

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Lanman & Kemp-Barclay & Co. of Colombia v. Commissioner of Internal Revenue, 26 TC 582 (1956)

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Words and Phrases
income tax

Commissioner v. American Metal Co. (1955), 221 F. 2d 134 (2d Cir. 1955), cert. denied 350 U.S. 829 (1955)

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B.C. Insurance Co. v. MNR, 54 DTC 422, 11 Tax A.B.C. 225

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Helvering v. Queen Insurance Co. (1940), 115 F. 2d 341 (2d Cir. 1940), cert. denied 312 U.S. 706 (1940)

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London County Council v. A.G., [1901] A.C. 26, 4 TC 265 (HL)

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Tax Topics - Statutory Interpretation - Legislative History 29

Administrative Policy

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 124
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) only income was taxable capital gains 131
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) s. 20(14) deduction for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 418
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 316
Tax Topics - Treaties - Articles of Treaties - Article 24 Treaty sourcing rule does not trench on domestic FTC 208

10 June 2016 STEP Roundtable Q. 9, 2016-0634941C6 - Support for US FTC Claims

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2015 Ruling 2015-0572541R3 - Foreign Tax Credit on Transfer of 401(k) to RRSP

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) s. 60(j) deduction does not reduce foreign source income for FTC purposes 187
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j) 21

2015 Ruling 2015-0570291R3 - Foreign tax credit on income from a trust

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) distribution of IRA proceeds by U.S.-resident trust is income under s. 104(13)(a) 291

23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) s. 40(3) gain had Cdn source/foreign tax not a "tax" if no refund sought 408
Tax Topics - Treaties - Articles of Treaties - Article 24 s. 40(3) gain had Cdn source 224

10 June 2013 STEP Roundtable, 2013-0480371C6 - 2013 STEP Question 13 - US LLCs and 20(11)

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S5-F2-C1 - Foreign Tax Credit

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19 April 2011 Memo 2011-0398741I7

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13 July 2004 External T.I. 2003-004908 -

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3 November 1998 External T.I. 5-981011 -

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16 September 1997 Background Paper for Round Table Question No. 9717730

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12 April 1995 T.I. 923714 (C.T.O. "Foreign Tax Credits - Consolidated Foreign Returns")

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23 March 1994 T.I. 933241 (C.T.O. "Japan Inhabitant's Tax - Income or Profits Tax (4093-J2)")

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29 March 1994 T.I. 931729 (C.T.O. "6359 for Tax Credit-Social Security")

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8 March 1994 T.I. 930294 (C.T.O. "Foreign Tax Credit-Social Security Contributions")

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10 February 1993 Memorandum (Tax Window, No. 29, p. 5, ¶2432)

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18 July 1991 Memorandum (Tax Window, No. 6, p. 15, ¶1359)

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6 May 1991 T.I. (Tax Window, No. 3, p. 27, ¶1240)

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Tax Topics - Income Tax Act - Section 9 - Nature of Income 34

20 March 1991 T.I. (Tax Window, No. 1, p. 19, ¶1157)

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25 March 1991 Memo 7-4727

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) US withholding on share redemption was income tax 81

15 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 23, ¶1021)

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90 C.P.T.J. - Q.10

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89 C.R. - Q.4

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88 C.R. - Q.57

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) Treaty inapplicability 38

IT-506 "Foreign Income Taxes as a Deduction from Income"

Articles

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

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Matthew Warren, Eileen Scott, Alan Fischl, Sergio Lugo Dimas, "U.S. Foreign Tax Credibility of the Mexican Cash Deposits Tax", Journal of International Taxation, October 2013, p. 37

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