Subsection 219(1) - Additional tax
IT-81R "Partnerships - Income of Non-Resident Partners"
A non-resident corporation which is a member of a partnership carrying on business in Canada is subject to the branch tax.
Gravelle, McAskile, "Conversion of a Branch to a Subsidiary and a Subsidiary to a Branch", 1993 Canadian Tax Journal, No. 6, p. 1180.
Subsection 219(1.1) - Excluded gains
Although the reference to taxable Canadian property is to be read without reference to paragraph (a) of the definition (real property situated in...
Subsection 219(2) - Exempt corporations
Twentieth Century Fox Film Corp. v. MNR, 2001 DTC 5125 (FCTD)
In rejecting a submission that the taxpayer, whose Canadian branch was responsible for distributing in Canada films, videos and other products...
|Locations of other summaries||Wordcount|
|Tax Topics - Income Tax Act - Section 164 - Subsection 164(1)||171|
"... Subparagraph 219(2)(b)(ii) of the Act grants tax relief to those non-resident corporations who own or rent a transmission facility in Canada...
Subsection 219(3) - Provisions applicable to Part
The taxpayer (a non-resident insure) transferred its Canadian insurance branch on a rollover basis to a wholly-0wned subsidiary, did not enter any...