Section 263

Table of Contents

Section 263
Subsection 263(1)
(j)
Administrative Policy(1)
(c)
Administrative Policy(1)
Subsection 263(2)
Administrative Policy(2)
Articles(1)
Finance
Subsection 263(3)
Administrative Policy(1)

Subsection 263(1)

(j)

Administrative Policy

Matias Milet, "FATCA and Canadian Investment Entities," Journal of International Taxation, March 2015, p. 29.

Breadth of Canadian IGA definition of "Investment Entity" (p. 33)

So long as an entity is managed by an asset manager or other institution that...

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(c)

Administrative Policy

Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020

3.46 ... [M]ost of the deemed-compliant FFI categories described in the U.S. Treasury Regulations will be of limited interest to Canadian...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Annex 1 - Section VI - Subparagraph B(4) 139
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 1 55
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 2 425
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(j) Investment Entity 104
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(l) Canadian Financial Institution 52
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(r) Nonparticipating Financial Institution 33
Tax Topics - Income Tax Act - Section 263 - Subsection 263(2) 125
Tax Topics - Income Tax Act - Section 263 - Subsection 263(3) 720
Tax Topics - Income Tax Act - Section 264 - Paragraph 264(1)(c) 316
Tax Topics - Income Tax Act - Section 265 - Subsection 265(2) 164
Tax Topics - Income Tax Act - Section 265 - Subsection 265(8) 531
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Investment Limited Partnership 130
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Annex 2 - Section III - Paragraph A 1216

Subsection 263(2)

Administrative Policy

10 September 2015 External T.I. 2015-0590061E5 - Money Services Business

Would Canco, which is a Canadian-based business that provides payment processing services to payors such as peer-to-peer money transfer services...

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Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020

3.34 ... An entity can be sure that it does not have reporting obligations under Part XVIII if it is not described in paragraphs (a) to (m) of the...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Annex 1 - Section VI - Subparagraph B(4) 139
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 1 55
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 2 425
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(j) Investment Entity 104
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(l) Canadian Financial Institution 52
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(r) Nonparticipating Financial Institution 33
Tax Topics - Income Tax Act - Section 263 - Subsection 263(1) - (c) 45
Tax Topics - Income Tax Act - Section 263 - Subsection 263(3) 720
Tax Topics - Income Tax Act - Section 264 - Paragraph 264(1)(c) 316
Tax Topics - Income Tax Act - Section 265 - Subsection 265(2) 164
Tax Topics - Income Tax Act - Section 265 - Subsection 265(8) 531
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Investment Limited Partnership 130
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Annex 2 - Section III - Paragraph A 1216

Articles

Kristen A. Parillo, "Canada's FATCA Guidance: Too Much Discretion Used?", Tax Notes International, July 14, 2014, p. 73

Canadian decision to exclude private trusts (p. 74)

Private trusts' exclusion from the listed financial institutions is made clear in Example C...

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Finance

A Finance official indicated that, in the course of the negotiations of the IGA with the U.S., the US tax authorities were informed of the...

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Subsection 263(3)

Administrative Policy

Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020

Nominee-name/client-name

5.3 When investment fund units are sold through dealers, they can be issued in the name of the beneficial owner...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Annex 1 - Section VI - Subparagraph B(4) 139
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 1 55
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 2 425
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(j) Investment Entity 104
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(l) Canadian Financial Institution 52
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Section 1 - 1(r) Nonparticipating Financial Institution 33
Tax Topics - Income Tax Act - Section 263 - Subsection 263(1) - (c) 45
Tax Topics - Income Tax Act - Section 263 - Subsection 263(2) 125
Tax Topics - Income Tax Act - Section 264 - Paragraph 264(1)(c) 316
Tax Topics - Income Tax Act - Section 265 - Subsection 265(2) 164
Tax Topics - Income Tax Act - Section 265 - Subsection 265(8) 531
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Investment Limited Partnership 130
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Annex 2 - Section III - Paragraph A 1216

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