Administrative Policy
17 May 2023 IFA Roundtable Q. 3, 2023-0964551C6 - T1134 Supplement
Finance indicated that given that ss. 90(2) and (5) provided a comprehensive definition of what constituted a dividend (namely, a pro rata...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | a pro rata distribution by an LLLP to its members is a dividend | 68 |
17 May 2023 IFA Roundtable Q. 2, 2023-0964301C6 - Ukraine Russia FAs and Tax Reporting
Will CRA grant any administrative relief in relation to the reporting requirements of Canadian multinationals for their subsidiaries in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) | potential relief from return-filing requirements re FA in war-torn country | 162 |
9 July 2015 External T.I. 2013-0475421E5 - Section 94.2
Where s. 94.2(2) deems a non-resident unit trust whose units are majority-owned by an investment dealer, or other taxpayer subject to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) | potential relief from penalties where insufficient data for computing FAPI | 191 |
| Tax Topics - Income Tax Act - Section 94.2 - Subsection 94.2(2) | deemed CFA unit trust sub of a FI subject to mark-to-market rules | 178 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.14) | no stated accommodation for using proxy method where data unavailable | 289 |