Subsection 233.4(1)
Paragraph 233.4(1)(c)
Administrative Policy
13 July 2016 External T.I. 2015-0608671E5 - Foreign Reporting Requirement under 233.4
A non-resident trust (“NRT”), which is factually resident in the U.S. but resident in Canada under s. 94(3)(a), owns over a 10% direct...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a) - Subparagraph 94(3)(a)(vi) | no T1134 filing obligation where a s. 94 trust holds an interest in a non-resident corp through an LP | 59 |
Subsection 233.4(4) - Returns respecting foreign affiliates
See Also
RAR Consultants Ltd. v. The Queen, 2017 TCC 214 (Informal Procedure)
The taxpayer (“RAR Canada”) was assessed under s. 162(7) for $12,500 in penalties for failure to file T1134 forms in respect of its specified...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | requirement for T1134 was not based on whether information otherwise available | 96 |
Administrative Policy
10 October 2024 APFF Roundtable, Q.5
The T1134 instructions indicate that to access the relief for related reporting entities, they should be related as per s. 251(4). A partnership...
10 October 2024 APFF Roundtable, Q.4
On April 30, 2023, Canco (resident in Canada) transferred all the shares of USco (resident in the US and which, in turn, wholly-owned a US LLC) to...
8 July 2013 External T.I. 2012-0458601E5 F - T1134 and inactive FA
Where an FA is the general partner of a partnership, is the $25,000 of gross receipts provided for in the definition of inactive FA in Form T1134...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(a) | partnership not a person for s. 233.4 purposes | 83 |
16 May 2018 IFA Roundtable Q. 10, 2018-0748161C6 - Proposed New Filing Deadline T1134
Will CRA provide relief under ss. 220(3) and (3.1) where taxpayers are unable to timely file their T1134 forms, including situations where there...
16 May 2018 IFA Roundtable Q. 9, 2018-0748151C6 - T1134s & Country by Country Reporting
Although the mandated requirement is a Finance requirement, what is CRA’s perspective on whether there is a need for T1134 filing in addition to...
26 April 2017 IFA Roundtable Q. 6, 2017-0691241C6 - T1134 filing issues
a) If two Canadian corporations with CFAs amalgamate, would CRA consider extending its administrative relief re the avoidance of duplicative...
15 May 2014 External T.I. 2014-0520091E5 - Form T1134
A non-resident corporation ("NRCo") distributed all its property during its 2012 taxation year on liquidation and was formally dissolved on...
23 May 2013 IFA Round Table, Q. 8(a)
Question and response are identical to 2013-0481401C6 below.
17 May 2013 CLHIA Roundtable, 2013-0481401C6 - Form T1134 - 2013 CLHIA Roundtable
Because "equity percentage" in s. 95(4) includes indirect share ownership, the reporting requirements could lead to a considerable administrative...
Articles
Joint Committee, "Reporting Requirements in Respect of Foreign Affiliates", 18 May 2018 Joint Committee Submission re accelerated T1134 filings
Budget 2018 proposed that the requirement in s. 233.4(4) to file T1134s within 15 months of year end be changed to 6 months respecting taxation...
Forms
T1134 "Information Return Relating To Controlled and Not-Controlled Foreign Affiliates (2011 and later taxation years)"
Do not file Form T1134 if...