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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 28 | 46 |
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...
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...
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...
| 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...
| 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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 278 - Subsection 278(2) | wire transfer account info should be confirmed by fax | 184 |
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...
| 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 |