2 October 89 Memorandum (March 1990 Access Letter, ¶1160)
GAAR did not apply to an arrangement whereby temporary Canadian employees of the Canadian subsidiary of a U.S. corporation contributed $3500 each...
"RRSP Withdrawals by U.S. Executives Temporarily Resident in Canada May Escape Canadian Withholding and Income Taxation", Taxation of Executive Compensation and Retirement, June 1990, p. 297
Further discussion of RCT October 1989 memorandum.
Subsection 217(2) - Part I return
Merrins v. The Queen, 2002 DTC 1848 (TCC)
In finding that the taxpayer (who was a resident of Ireland in receipt of both Canadian old age security payments and also pension income that...
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