Subsection 212(1)

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Cases

Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 59

The Queen v. Immobiliare Canada Ltd., 77 DTC 5332, [1977] CTC 481 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) sale proceeds allocable to expectancy of interest were not interest receipt 126
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) 89
Tax Topics - Income Tax Act - Section 76 103

See Also

Richard Lewin Re: The J.J. Herbert Family Trust #1 v. The Queen, 2011 DTC 1354 [at 1979], 2011 TCC 476, aff'd 2013 DTC 5006 [at 5525], 2012 FCA 279 [but overridden by s. 214(3)(f)(i)(C)]

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Words and Phrases
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La Compagnie Minière Québec Cartier v. M.N.R., 84 DTC 1348 (TCC)

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Administrative Policy

14 July 2015 External T.I. 2013-0499621E5 - Paragraph 212(1)(d) and Credited

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17 May 2012 IFA Roundtable Q. 2, 2012-0444051C6 - 2012 IFA Seminar - Q.2 Reduced Tax Withholdings

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27 August 2012 External T.I. 2011-0416181E5 - US internet publisher - CDN resident advertiser

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Income Tax Technical News, No. 14, "Meaning of 'Credited' for the Purpose of Part XIII Withholding Tax" (CANCELLED).

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12 June 1996 T.I. 961979

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5 January 1996 Memorandum 952397 (C.T.O. "Gross-Up Payments")

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October 1995 Memorandum 951626

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26 April 1995 T.I. 950216 (C.T.O. "Systems/Operating Software")

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17 October 1994 T.I. 941807 (C.T.O. "Withholding Tax") and 15 June 1994 T.I. 941096 (C.T.O. "Withholding Tax")

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15 April 1994 T.I. 940290 (C.T.O. "Withholding Tax Exemption on Medium Term Debt")

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91 C.R. - Q.48

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19 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 22, ¶1040)

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July 1990 Memorandum

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86 C.R. - Q.84

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84 C.R. - Q.17

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84 C.R. - Q. 60

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IC 77-16R4 "Non-Resident Income Tax", para. 5

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Articles

Steve Suarez, "Canada Extends Transition Period for Treaty-Reduced Nonresident Withholding", Tax Notes International, 27 February 2012

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Forms

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