Section 133

Subsection 133(1) - Computation of income

Cases

MNR v. Peninsular Investments Ltd., 63 DTC 1149 (Ex Ct)

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Administrative Policy

5 March 1990 T.I. (August 1990 Access Letter, ¶1383)

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Articles

Rohde, "NROs - Some New Developments", Tax Profile, Vol. 4, No. 34, April 1996, p. 382.

Lanthier, "Acquiring, Holding and Financing Canadian Corporations", Bulletin for International Fiscal Documentation, Vol. 48, No. 8/9, August/September 1994, Special IFA issue, p. 419.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 13 5

Broadhurst, "Financing by Non-Residents", 1992 Corporate Management Tax Conference Report, c. 9.

Aud, "Tax Havens - What Benefits Still Exist?", International Tax Report, August 1992

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McGuffin, "Financing a Canadian Subsidiary Through an NRO", The Journal of International Taxation, November/December 1991, p. 235.

Subsection 133(8) - Definitions

Cumulative Taxable Income

Cases

Great Atlantic and Pacific Tea Co. Ltd. v. The Queen, 79 DTC 5401, [1979] CTC 509, [1980] 1 S.C.R. 670

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Non-Resident-Owned Investment Corporation

Cases

Banner Pharmacaps NRO Ltd. v. Canada, 2003 FCA 367, 2003 DTC 5642 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt promissory note accepted as payment 133
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(j) dividends recognized on cash basis 111

Deltona Corp. v. MNR, 71 DTC 5186, [1971] CTC 297 (Ex Ct), briefly aff'd 73 DTC 5180, [1973] CTC 215 (SCC)

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See Also

No. 479 v. MNR, 58 DTC 9, 18 Tax ABC 272

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Administrative Policy

5 November 1999 Memorandum 991063

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Words and Phrases
loan

5 July 1995 External T.I. 5-950242 -

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18 February 1994 T.I. 932405 (C.T.O. "NRO - 'Making of a Loan' (HAA) 6666-1)")

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23 November 1992 T.I. 920625 (September 1993 Access Letter, p. 421, ¶C117-205)

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Words and Phrases
trading

October 1992, Central Region Rulings Directorate Tax Seminar, Q. E (May 1993 Access Letter, p. 229)

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16 September 1992 T.I. (Tax Window, No. 24, p. 14, ¶2193)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 71

ATR-43, February 17, 1992

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