Section 157

Subsection 157(1) - Payment by corporation

Cases

MNR v. Kayelle Management (Yukon) Inc., 94 DTC 6116, [1994] 1 CTC 271 (FCA)

The taxpayer, which was a Canadian-controlled private corporation, had a fiscal year-end of February 1, 1990. It was not required to pay the final...

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Words and Phrases
month

Administrative Policy

8 October 2010 Roundtable, 2010-0373701C6 F - Affectation de paiement par l'ARC

A cheque received by the CRA can be mistakenly applied to current year instalments rather than to tax payable. How can this be avoided? CRA...

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25 January 1991 Memorandum (Tax Window, Prelim. No. 3, p. 31, ¶1108)

An administrative policy permits a reduction in instalment requirements to the extent of tax withheld at source under Regulation 105 on payments...

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Paragraph 157(1)(a)

Administrative Policy

21 January 2015 Internal T.I. 2014-0540631I7 - S.261 and loss carryback request

CRA indicated that it generally will apply the instalment method that minimizes the Canadian dollar taxes payable when it assesses for...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 261 - Subsection 261(11) - Paragraph 261(11)(a) CRA applies most favourable instalment method in assessing for carried-back losses of a functional currency reporter 569

Paragraph 157(1)(b)

Cases

Quinco Financial Inc. v. Canada, 2018 FCA 137

After rejecting a submission that no interest accrued by virtue of a GAAR reassessment between the balance-due date of a taxation year for which a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 161 - Subsection 161(1) interest is added as usual to a GAAR assessment 322
Tax Topics - Income Tax Act - Section 245 - Subsection 245(2) taxpayers do not “apply” GAAR, but GAAR liability accrues before reassessment 284

Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable, Q.13

CRA observed that because “intermediary banks often have a limit on the number of characters allowed in [a wire transfer] transaction, so this...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 278 - Subsection 278(2) wire transfer account info should be confirmed by fax 174

Subsection 157(1.2)

Paragraph 157(1.2)(a)

Administrative Policy

16 October 2012 External T.I. 2011-0425271E5 F - Small CCPC

A Canadian-controlled private corporation (CCPC), required to pay monthly instalments in respect of a particular taxation year, carried back a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 5301 - Subsection 5301(4) - Paragraph 5301(4)(a) Amalco’s instalments based on tax payable of predecessors 294
Tax Topics - Income Tax Regulations - Regulation 5301 - Subsection 5301(6) - Paragraph 5301(6)(a) flow-through of attributes of wound-up sub 192
Tax Topics - Income Tax Regulations - Regulation 5301 - Subsection 5301(8) - Paragraph 5301(8)(a) 1st instalment base of transferor taken into account by transferee 206