Section 211.91

Subsection 211.91(1)

Cases

Tusk Exploration Ltd. v. Canada, 2018 FCA 121

For its 2002 to 2006 years, the taxpayer (“Tusk Exploration” - a Canadian exploration company) renounced Canadian exploration expenses...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) potential for double taxation under the ITA of NAL transactions 307
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) double taxation can result from non-arm’s length transactions such as under s. 69(1) 301
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.6) only a PBC can renounce 61

See Also

Tusk Exploration Ltd. v. The Queen, 2016 TCC 238

The taxpayer, which was assessed under Part XII.6 for applying the look-back rule in s. 66(12.66) to Canadian exploration expenses (CEE) which...

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Words and Phrases
purports

Subsection 211.91(2.1)

Administrative Policy

24 February 2021 Internal T.I. 2020-0870401I7 - Application of Part XII.6 tax re Draft legislation

In January 2020, a principal-business corporation (“PBC”) renounces (with an effective date of December 31, 2019, under the look-back rule)...

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23 December 2020 External T.I. 2020-0874621E5 - Administration of Draft Legislation-FTS Extension

Regarding the proposed amendments (principally ss. 66(12.6001), 66(12.731) and 211.91(2.1)) released on December 16, 2020 generally relating to a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.731) filings can be made relying on draft COVID extensions 188