Subsection 219(1) - Additional tax
Administrative Policy
21 October 2021 Internal T.I. 2020-0872281I7 - S.219 and Article X(6) of the Canada-US Treaty
The Directorate confirmed the position in 9408985 that in light of the branch profits limitation under Ar. X(6) of the Canada-US Treaty of 10% of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 10 | different treatment of losses under Pt. XIV and Art. X(6) of the Canada-US Treaty and of investment allowance | 338 |
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.
Articles
Gravelle, McAskile, "Conversion of a Branch to a Subsidiary and a Subsidiary to a Branch", 1993 Canadian Tax Journal, No. 6, p. 1180.
Forms
Subsection 219(1.1) - Excluded gains
Administrative Policy
28 July 2008 External T.I. 2008-0298011E5 - Branch Tax - Section 219
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
Cases
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 |
Administrative Policy
28 February 1995 External T.I. 9421715 - COMMUNICATIONS AND BRANCH TAX
"... 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
Administrative Policy
23 April 2012 Internal T.I. 2011-0426601I7 - Part XIV tax - non-resident insurer
The taxpayer (a non-resident insure) transferred its Canadian insurance branch on a rollover basis to a wholly-0wned subsidiary, did not enter any...