Section 144

Subsection 144(1) - Definitions

Articles

Jack Bernstein, "Employee Profit Sharing Plans", Tax Profile, Vol. 5, No. 23, July 1998, p. 265.

Employee Profit Sharing Plan

Cases

Gary Jackson Professional Corporation v. Canada (National Revenue), 2013 DTC 5108 [at 6082], 2013 FCA 142

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See Also

Dimane Enterprises Ltd. v. The Queen, 2015 DTC 1013 [at 64], 2014 TCC 334

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt payments not received where children "recipients" had no control over funds 58
Tax Topics - General Concepts - Sham purported recipients of trust distributions had no control over funds 236

Administrative Policy

11 February 2019 External T.I. 2018-0738561E5 - Employer contributions

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11 March 2014 External T.I. 2013-0503771E5 - EPSP

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14 November 1996 T.I. 963555 (C.T.O. "EPSP Expenses Reducing Employer Contributions")

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24 June 1994 T.I. 941306 (C.T.O. "Forfeitures Under EPSP")

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19 August 1992 External T.I. 5-922039 -

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Subsection 144(3) - Allocation contingent or absolute taxable

Administrative Policy

13 January 1993 T.I, (Tax Window, No. 28, p. 17, ¶2384)

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9 April 1992 T.I. (Tax Window, No. 18, p. 9, ¶1856)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 144 - Subsection 144(8) 31

IT-379 "Employees Profit Sharing Plans - Allocations to Beneficiaries"

Subsection 144(7) - Beneficiary’s receipts that are not deductible

Administrative Policy

October 1995 Memorandum 951626

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Subsection 144(8) - Allocation of credit for dividends

Administrative Policy

October 1995 Memorandum 951626

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9 April 1992 T.I. (Tax Window, No. 18, p. 9, ¶1856)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 144 - Subsection 144(3) 23

Subsection 144(8.1)

Paragraph 144(8.1)(b)

Administrative Policy

31 January 2018 External T.I. 2016-0676431E5 - foreign tax credit on employees profit sharing

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(1) $200 basket for NBIT for which country-by-country reporting is not required includes flow-through EPSP taxes 145
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) no s. 20(11) deduction for foreign taxes respecting EPSP income allocated to beneficiary 101
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) no s. 20(12) deduction to EPSP beneficiary 102

Subsection 144(10) - Payments out of profits

Administrative Policy

19 November 1996 T.I. 963734 (C.T.O. "Retroactive 144(10) Election")

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2 March 1992 External T.I. 5-912899 -

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IT-280R "Employees Profit Sharing Plans - Payments Computed by Reference to Profits"