Section 215

Subsection 215(1) - Withholding and remittance of tax

See Also

Curragh Inc. v. The Queen, 94 DTC 1894 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 215 - Subsection 215(3) 139
Tax Topics - Income Tax Act - Section 216 - Subsection 216(4) s. 216 does not relieve payor of liability 103

Nestle Enterprises Ltd. v. MNR, 92 DTC 1001 (TCC)

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Words and Phrases
forthwith remit

Administrative Policy

16 August 2017 Internal T.I. 2015-0622751I7 - Part XIII Tax on Benefit to Non-resident

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(9) s. 15(9) applies to interest-free loan between two foreign affiliates 257
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) use of s. 160 to collect s. 15(9) liability of indirect FA on dividends paid to Canco 269
Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) s. 227.1 liability can extend to NR directors of a CFA 168
Tax Topics - Income Tax Act - Section 214 - Subsection 214(3) - Paragraph 214(3)(a) benefit from interest free loan by CFA to Canco sister deemed to be a dividend subject to Pt XIII tax 160
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(2) extra-territorial application of s. 80.4(2) 132

IT-494 "Hire of Ships and Aircraft from Non-Residents"

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IC 77-16R3 "Non-Resident Income Tax"

IC 76-12R4

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Forms

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Subsection 215(2) - Idem [Exception - corporate immigration]

See Also

Havlik Enterprises Ltd. v. MNR, 89 DTC 159 (TCC)

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Administrative Policy

IC-12R4 "Applicable Rate of Part XIII Tax on Amounts Paid or Credited to Persons in Treaty Countries" under "Beneficial Ownership"

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Subsection 215(3) - Idem [Exception - corporate immigration]

Cases

Chilcott v. The Queen, 78 DTC 6111, [1978] CTC 152 (FCTD)

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See Also

Curragh Inc. v. The Queen, 94 DTC 1894 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 215 - Subsection 215(1) agent's s. 215(3) liability does not relieve taxpayer's s. 215(1) liability 139
Tax Topics - Income Tax Act - Section 216 - Subsection 216(4) s. 216 does not relieve payor of liability 103

Subsection 215(6) - Liability for tax

Cases

Cardinal Meat Specialists Ltd. v. Devereux, 92 DTC 6357 (Ont CA)

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See Also

Solomon v. The Queen, 2007 DTC 1715, 2007 TCC 654 (Informal Procedure)

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Havlik Enterprises Ltd. v. MNR, 89 DTC 159 (TCC)

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Administrative Policy

2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date no ruling on price adjustment clause 129
Tax Topics - Income Tax Act - Section 52 - Subsection 52(2) taxable dividend spin-off of thinly capitalized sub 249

16 November 2011 External T.I. 2011-0419191E5 - Foreign Intermediaries & Canadian Owners

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