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