Subsection 56(1) - Amounts to be included in income for year
Paragraph 56(1)(a) - Pension benefits, unemployment insurance benefits, etc.
Cases
Woods v. The Queen, 2010 DTC 1095 [at 2996], 2010 TCC 106, aff'd 2011 DTC 5049 [at 5681], 2011 FCA 90
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit | 127 |
Watts v. The Queen, 2004 DTC 3111, 2004 TCC 535 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.94 | 37 | |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | 71 |
Subparagraph 56(1)(a)(i)
Cases
Burchill v. Canada, 2010 DTC 5096 [at 6922], 2010 FCA 145
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Context | 93 |
See Also
Rasmussen v. The Queen, 2019 TCC 124 (Informal Procedure)
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Mammone v. The Queen, 2018 TCC 24, rev'd 2019 FCA 45
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | RPP revocation beyond the normal reassessment period retroactively validated an unsupportable reassessment under s. 56(1)(a)(i) | 398 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | subsequent retroactive deregistration of RPP also retroactively validated an assessment factually made on basis of plan’s invalidity | 200 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | subsequent retroactive deregistration of RPP would not establish carelessness in previous return filing | 185 |
| Tax Topics - General Concepts - Effective Date | subsequent deregistration of RPP retroactively validated reassessment | 223 |
| Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(12) | subsequent deregistration of RPP beyond normal reassessment period nonetheless retroactively validated reassessment | 91 |
Gill v. The Queen, 2012 DTC 1261 [at 3764], 2012 TCC 302
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "including without limitation" is expansive | 159 |
Brilla v. The Queen, 98 DTC 1502 (TCC)
Walker v. The Queen, 95 DTC 753 (TCC)
Administrative Policy
12 September 2019 External T.I. 2019-0802301E5 - Annuity purchased from foreign pension
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 147.4 - Subsection 147.4(1) | s. 147.4(1) permits non-inclusion where annuity is purchased out of RPP | 146 |
2 April 2019 Internal T.I. 2016-0649821I7 F - Unclaimed superannuation or pension benefits
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 | 352 |
12 April 2018 External T.I. 2016-0640651E5 F - Swiss Pension
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - superannuation or pension fund or plan | Swiss vested benefits policy was a “superannuation or pension fund or plan” | 285 |
10 April 2014 External T.I. 2013-0515681E5 - Death of RPP Member-56(1)(a)
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19 March 2014 External T.I. 2014-0522671E5 - HK Pension and Tax Treaty
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25 June 2012 External T.I. 2011-0398691E5 - Conversion of U.S. Traditional IRA into Roth IRA
19 June 2012 External T.I. 2011-0407461E5 - Tax on 401(k) Transfer to IRA and IRA Withdrawal
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3 March 2004 External T.I. 2003-004715 -
16 January 1996 T.I. 952921 (Tax Window Files "401(k), Double Tax in Canada")
27 October 1994 T.I. 942712 (C.T.O. "Deferral of Lump Sum Severance Payment")
20 November 1991 T.I. (Tax Window, No. 13, p. 9, ¶1601)
7 March 1991 T.I. (Tax Window, No. 1, p. 21, ¶1151)
8 September 89 T.I. (February 1990 Access Letter, ¶1097)
88 C.R. - Q.5
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 18 | 50 |
Clause 56(1)(a)(i)(C.1)
See Also
McKenzie v. The Queen, 2017 TCC 56 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6803 | an IRA which is a custodial arrangement is included | 205 |
Administrative Policy
29 October 2018 External T.I. 2018-0750411E5 - Transfer from an IRA to a RRSP
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 60.01 | a departing U.S. resident who has a deemed inclusion for his IRA cannot then obtain a s. 60(j) deduction for contributing actual IRA withdrawals to his RRSP | 298 |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j) | failure to qualify for 60(j) deduction where deemed withdrawal from IRA followed by actual withdrawal | 153 |
29 January 2018 External T.I. 2017-0682301E5 - Deemed Distribution and Withdrawal from IRA
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | deemed Code taxability of IRA on renouncing U.S. citizenship generally would generate an FTC to deemed Cdn-resident recipient | 119 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(12) | deemed ITA inclusion on deemed distribution from IRA on renouncing U.S. citizenship or relinquishing green card | 76 |
Subparagraph 56(1)(a)(iii)
See Also
Scott v. The Queen, 2017 TCC 224, 2017 TCC 224
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 89 - Subsection 89(1) - Paragraph 89(1)(a) | trust return not admitted at trial opening where no previous notice and not relied upon by CRA | 211 |
| Tax Topics - Income Tax Act - 101-110 - Section 107.1 - Paragraph 107.1(a) | s. 107.1(a) in effect produced a rollover on cash distribution of mooted benefits | 175 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | a distribution from a health and welfare trust to compensate for lost insurance coverage was not a taxable benefit as it did not come within s. 6(4) | 304 |
| Tax Topics - General Concepts - Stare Decisis | Supreme Court obiter accorded deference | 129 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | surrogatum principle references "why the compensatory amount was paid," and not confined to business receipts | 191 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | termination payment that did not come within s. 6(4) should be treated as excluded from s. 6(1)(a) | 141 |
Subparagraph 56(1)(a)(ii)
Cases
Doyle v. The Queen, 83 DTC 5383, [1983] CTC 339 (FCTD)
Lawson v. The Queen, 82 DTC 6331, [1982] CTC 368 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 21 |
Administrative Policy
Paragraph 56(1)(b) - Support
Cases
Tossell v. Canada, 2005 DTC 5365, 2005 FCA 223
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount | 271 |
The Queen v. Jasper, 94 DTC 6519 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Estoppel | 109 |
The Queen v. Sigglekow, 85 DTC 5471 (FCTD)
The Queen v. Sills, 85 DTC 5096, [1985] 1 CTC 49 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) - Paragraph 15(1)(b) | 51 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(b) | 51 |
See Also
Welch v. The Queen, 2012 DTC 1288 [at 3892], 2012 TCC 350 (Informal Procedure)
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Blais v. MNR, 92 DTC 1497 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | payment references funds transfer | 94 |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 94 |
Morley-Clarke v. Jones, [1985] BTC 460 (C.A.)
The Queen v. Sills, 85 DTC 5096, [1985] 1 CTC 49 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) - Paragraph 15(1)(b) | 51 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(b) | 51 |
Articles
Durnford, Toope, "Spousal Support in Family Law and Alimony in the Law of Taxation", Canadian Tax Journal, 1994, Vol. 42, No. 1, p. 1.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) - Paragraph 15(1)(b) | 0 | |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 0 |
Paragraph 56(1)(c)
Paragraph 56(1)(d) - Annuity payments
Cases
The Queen v. Rumack, 92 DTC 6142 (FCA)
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See Also
Short v. The Queen, 99 DTC 1146 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Annuity | 107 |
Administrative Policy
30 March 2017 External T.I. 2015-0609951E5 F - Article 18 of the Canada-Turkey Income Tax Convention
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 18 | capital portion of s. 56(1)(d) is not excluded as an annuity under Canada-Turkey Treaty/RRSP annuity payments are pensions | 382 |
| Tax Topics - Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 5 - Pension | RRSP annuity payments to Turkish resident were subject to Pt XIII tax as pension payments | 44 |
20 May 1994 T.I. 940504 (C.T.O. "Structured Settlement under No-Fault Insurance")
29 January 1993 T.I. 9200395 (Tax Window, No. 27, p. 1, ¶2360)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 138 | |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 138 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 138 |
22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360)
29 October 1992 T.I. 922997 (September 1993 Access Letter, p. 414, ¶C56-252)
21 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 28, ¶1099)
ATR-40 (18 March 1991) "Structured Settlements"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 | 15 | |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 15 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 15 |
Paragraph 56(1)(h) - Registered retirement savings plan, etc.
Paragraph 56(1)(l.1) - Idem [Legal expenses]
Cases
Administrative Policy
8 October 1996 T.I. 962701 (C.T.O. "Loss of Employment, Mental Distress, Damages")
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | 109 | |
| Tax Topics - Income Tax Regulations - Regulation 100 - Subsection 100(1) - Remuneration | 14 |
Paragraph 56(1)(n) - Scholarships, bursaries, etc.
Cases
Simser v. Canada, 2005 DTC 5001, 2004 FCA 414
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) | 106 |
The Queen v. Savage, 83 DTC 5409, [1983] CTC 393, [1983] 2 S.C.R. 428
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 83 | |
| Tax Topics - Statutory Interpretation - Redundancy/reading in words | exclusion in specific provision extended to general provision to avoid redundancy | 32 |
The Queen v. McLaughlin, 78 DTC 6406, [1978] CTC 602 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Official Languages Act - Section 13 | 70 |
See Also
Lewis v. The Queen, 2013 DTC 1117 [at 620], 2013 TCC 137 (Informal Procedure)
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Caropreso v. The Queen, 2012 DTC 1190 [at 3488], 2012 TCC 212 (Informal Procedure)
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Huang v. The Queen, 2012 DTC 1120 [at 3103], 2012 TCC 81 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(o) | 9 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(3) | 175 |
Chabaud c. La Reine, 2012 DTC 1076 [at 2856], 2011 TCC 438 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Substance | labels not deterinative | 58 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 166 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(o) | 48 |
Administrative Policy
22 February 2012 External T.I. 2011-0424601E5 F - Scholarships and bursaries paid by a firm
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | employer-reimbursed tuition not considered for its training benefit if incurred before employment commenced | 338 |
S1-F2-C2 - Tuition Tax Credit
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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6 May 2009 External T.I. 2008-0295581E5 F - Bourses et aide financière aux médecins
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | s. 12(1)(x) inclusion of assistance to foreign doctors to become licensed so that they will practise in a remote area | 64 |
20 June 1994 Internal T.I. 7-940939 -
3 December 1993 T.I. 932658 (C.T.O. "Allowances Paid by CIDA to Foreign Students and Trainees")
20 August 1992, T.I. (Tax Window, No. 23, p. 22, ¶2160)
6 April 1992 T.I. 920399 (March 1993 Access Letter, p. 69, ¶C56-215; Tax Window, No. 18, p. 22, ¶1859)
84 C.R. - Q.22
IT-75R3 "Scholarships, Fellowships, Bursaries, Prizes, and Research Grants".
Articles
Mark Dumalski, Dimitri Sarabalos, "Are Payments to Research Assistants Tax-Free?", Canadian Tax Focus, Vol. 3, No. 2, May 2013, p. 11
Jack Bernstein, "Scholarships: The Enhanced Employee Incentive", CCH Tax Topics, No. 1909, 9 October, 2008
Paragraph 56(1)(o) - Research grants
Cases
See Also
Huang v. The Queen, 2012 DTC 1120 [at 3103], 2012 TCC 81 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) | 109 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(3) | 175 |
Chabaud c. La Reine, 2012 DTC 1076 [at 2856], 2011 TCC 438 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Substance | labels not deterinative | 58 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 166 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) | 300 |
Administrative Policy
31 July 2014 External T.I. 2013-0509291E5 - Research grants
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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24 June 2011 External T.I. 2011-0409741E5 F - Déductions d'impôt sur une bourse de recherche
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 20 | assistance received by unenrolled Chinese student towards Ph.D. thesis research assistance was Treaty-exempt | 114 |
23 March 2011 External T.I. 2010-0382351E5 F - Bourses d'études ou subventions de recherche
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IT-75R3 "Scholarships, Fellowships, Bursaries, Prizes, and Research Grants".
Paragraph 56(1)(r) - Financial assistance
Administrative Policy
17 July 2015 External T.I. 2014-0517091E5 - Wage Subsidies
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17 July 2015 External T.I. 2014-0517081E5 - Assistance for individuals with disabilities
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) | federal assistance to those with disabilities | 143 |
4 March 2015 Internal T.I. 2014-0527751I7 F - Soutien de revenu accordé aux individus
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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance
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Paragraph 56(1)(u) - Social assistance payments
Cases
Simser v. Canada, 2005 DTC 5001, 2004 FCA 414
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) | 128 |
Administrative Policy
17 July 2015 External T.I. 2014-0517081E5 - Assistance for individuals with disabilities
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(r) | federal assistance to those with disabilities | 144 |
29 July 2015 External T.I. 2015-0575631E5 - social assistance
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 | payments in kind by social assistance organization | 81 |
| Tax Topics - Income Tax Regulations - Regulation 233 - Subsection 233(2) | potential exclusion of payments in kind | 245 |
14 February 2014 Internal T.I. 2013-0495661I7 - Taxability of payment from US charitable trust
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) | financial assistance to former charity employee | 86 |
2 September 2011 Internal T.I. 2011-0419111I7 F - Programme de compensation du MESS
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13 January 1992 T.I. (Tax Window, No. 15, p. 21, ¶1696)
16 August 1991 T.I. (Tax Window, No. 7, p. 16, ¶1394)
Paragraph 56(1)(v) - Workers’ compensation
Cases
Canada v. Whitney, 2002 DTC 7145, 2002 FCA 266
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 59 |
Administrative Policy
22 February 2012 External T.I. 2011-0421671E5 F - Loss of retirement income benefit - death
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| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(ii) | deduction for WSIB compensation paid to estate of deceased injured worker | 152 |
IT-202R2 "Employees' or Workers' Compensation
Paragraph 56(1)(x) - Retirement compensation arrangement
Administrative Policy
8 June 1993 Memorandum (Tax Window, No. 32, p. 17, ¶2614)
Subsection 56(2) - Indirect payments
Cases
Ludmer v. Attorney General of Canada, 2018 QCCS 3381
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | nature of the legal advice relied upon was unclear | 405 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | improper advancing of “settlement” elements that were not sustainable | 43 |
| Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) | equity-linked notes held in BVI company were portfolio investments held with a tax avoidance purpose, but were not subject to 7000(2)(d) interest accrual | 540 |
| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) | mere possibility of locking in value accretion each year did not crystallize the maximum amount of interest respecting the year | 454 |
| Tax Topics - General Concepts - Negligence and Fiduciary Duty | damages awarded against CRA for inter alia making unreasonable reassessments | 252 |
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | recurring fee reduction amounts received for no work were income from a source | 299 |
Lambert v. Canada, 2005 DTC 5499, 2004 FCA 389
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James v. Canada, 2001 DTC 5075 (FCA)
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|---|---|---|
| Tax Topics - General Concepts - Audit Procedure | 99 | |
| Tax Topics - General Concepts - Evidence | 50 | |
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | vacating not a remedy for lack of due dispatch | 84 |
Neuman v. M.N.R., 98 DTC 6297, [1998] 1 S.C.R. 770
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| Tax Topics - Statutory Interpretation - Provincial Law | 53 |
Jones v. The Queen, 96 DTC 6016 (FCA)
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| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 71 |
Smith v. The Queen, 93 DTC 5351 (FCA)
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | 37 |
Dixon v. Deputy Attorney General of Canada, 91 DTC 5584 (Ont HCJ.)
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| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 158 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | common directing mind | 73 |
The Queen v. Fairey, 91 DTC 5230 (FCTD)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 70 |
Mcclurg v. Canada, 91 DTC 5001, [1990] 3 S.C.R. 1020
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| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 60 |
Winter v. The Queen, 90 DTC 6681 (FCA)
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | s. 56(2) applied to taxpayer rather than 15(1) to son-in-law as de minimis shareholder | 70 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(2) | specific provisions applied before GAAR | 96 |
R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.)
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| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Subsection 15(1) | 45 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | benefit based on actual rather than subjective value | 91 |
Boardman v. The Queen, 85 DTC 5628, [1986] 1 CTC 103 (FCTD)
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| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 67 | |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) | 32 |
The Queen v. Hoffman, 85 DTC 5508, [1985] 2 CTC 347 (FCTD)
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De Groote v. The Queen, 85 DTC 5008, [1985] 1 CTC 687 (FCTD)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 92 | |
| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | no longer beneficial shareholder | 74 |
The Queen v. Chrapko, 84 DTC 6544, [1984] CTC 594 (FCTD), rev'd 88 DTC 6487, [1988] 2 CTC 342 (FCA)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Court Rules - Rule 420 [Amendment of Pleadings] | 36 | |
| Tax Topics - Income Tax Act - Section 67 | 69 |
Barbeau v. The Queen, 81 DTC 5379, 84 DTC 6148, [1981] CTC 496 (FCTD)
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| Tax Topics - Income Tax Act - Section 177 - Subparagraph 177(b)(iv) | 82 |
Champ v. The Queen, 83 DTC 5029, [1983] CTC 1 (FCTD)
Cox v. The Queen, 82 DTC 6287, [1982] CTC 322 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | 84 |
Fraser Companies, Ltd. v. The Queen, 81 DTC 5051, [1981] CTC 61 (FCTD)
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Murphy v. The Queen, 80 DTC 6314, [1980] CTC 386 (FCTD)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 44 | |
| Tax Topics - Income Tax Act - Section 74.1 - Subsection 74.1(1) | 93 |
McClain Industries of Canada Inc. v. The Queen, 78 DTC 6356, [1978] CTC 511 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 97 |
Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA)
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 112 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | 30 | |
| Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) | 52 |
Nelson v. The Queen, 74 DTC 6266, [1974] CTC 360 (FCA)
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| Tax Topics - General Concepts - Effective Date | 185 |
The Queen v. Quinn, 73 DTC 5215, [1973] CTC 258 (FCTD)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 85 | |
| Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) | 94 |
See Also
Fournier v. Agence du revenu du Québec, 2018 QCCQ 786
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| Tax Topics - General Concepts - Rectification & Rescission | taxpayer could reverse an assessment for a taxable benefit by subsequently engaging in self-help rectification | 355 |
Gainor v. The Queen, 2011 DTC 1317 [at 1798], 2011 TCC 442
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| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 162 |
Delso Restoration Ltd. v. The Queen, 2011 DTC 1315 [at 1786], 2011 TCC 435 (Informal Procedure)
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D'Andrea v. The Queen, 2011 DTC 1234 [at 1356], 2011 TCC 298
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | fraud conviction did not establish neglectful reporting | 183 |
Sochatsky v. The Queen, 2011 DTC 1065 [at 346], 2011 TCC 41, 2012 TCC 65
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| Tax Topics - General Concepts - Payment & Receipt | bonus booked as loan back/constructive receipt | 129 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 182 |
GlaxoSmithKline Inc. v. The Queen, 2008 DTC 3957, 2008 TCC 324
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Laflamme v. The Queen, 2008 DTC 482, 2008 TCC 255
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| Tax Topics - General Concepts - Fair Market Value - Shares | 196 |
Ceco Operations Ltd. v. The Queen, 2006 DTC 3006, 2006 TCC 256
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| Tax Topics - General Concepts - Substance | 95 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 266 | |
| Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) | partnership subscription for taxpayer affiliate pref shares not boot | 259 |
Speer v. The Queen, 99 DTC 157 (TCC)
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| Tax Topics - Income Tax Act - Section 129 - Subsection 129(1.2) | 35 |
Ferrel v. The Queen, 97 DTC 1565 (TCC)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 63 |
Gilvesy v. The Queen, 96 DTC 1417 (TCC)
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| Tax Topics - General Concepts - Fair Market Value - Other | 51 |
Paxton v. The Queen, 95 DTC 179 (TCC), rev'd 97 DTC 5012 (FCA)
Placements T.S. Inc. v. The Queen, 94 DTC 1302 (TCC)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 108 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 124 |
Béliveau v. MNR, 91 DTC 669 (TCC)
Administrative Policy
8 June 2018 Internal T.I. 2017-0683021I7 - Assignment of capital interest in a trust
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| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | purported drop-down of trust interests to an excluded beneficiary resulted in s. 104(13) inclusions to transferors | 327 |
| Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(5) | purported drop down of trust interests by non-resident beneficiaries to ULC was ineffective so that s. 107(2.1) applied to subsequent purported asset distribution to ULC | 186 |
| Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | potential application of s. 105(1) to income distribution to non-qualifying transferee of trust interest | 265 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(25) - Paragraph 248(25)(a) | para. (a) refers to beneficiary in ordinary sense - and does not include assignee | 56 |
28 October 2016 External T.I. 2016-0654331E5 F - Transfer of rights to income
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| Tax Topics - Income Tax Act - Section 9 - Nature of Income | where rental lands purchased subject to obligation to pay the rents to vendor, rents did not have quality of income to purchaser under s. 9 | 159 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | where rental lands purchased subject to obligation to pay the rents to vendor, no income inclusion and deduction of the rents by the purchaser under ss. 9 and 18(1)(a) | 83 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | where rental lands purchased subject to obligation to pay the rents to NAL vendor, s. 56(4) trumps s. 9 to include rents in purchaser’s income | 157 |
6 December 2016 External T.I. 2016-0666841E5 F - Sale of property for POD less than FMV
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) | application to Holdco shareholder of Opco where Opco conferrred a benefit on child of Holdco's shareholder | 200 |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | s. 246(1) applicable to indirect shareholder benefit if direct shareholder influenced the benefit conferral | 193 |
14 March 2016 External T.I. 2016-0626781E5 - Neuman Type Situation
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | s. 15(1) might apply where spouse subscribes nominal consideration for Opco shares and receives a large discretionary dividend | 214 |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | Kieboom treated as entailing disposition of right to receive dividends | 316 |
| Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) | spousal rollover for Kieboom disposition of economic interest | 68 |
24 June 2015 External T.I. 2015-0575911E5 F - Benefit to shareholder or conferred on a person
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) | benefit only conferred on one shareholder (the husband) if wife of one of four sibling shareholders receives benefit | 303 |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | benefit conferred on spouse of individual shareholder of parent | 137 |
S2-F3-C1 - Payments from Employer to Employee
10 April 2014 External T.I. 2013-0514321E5 - Donated vacation
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | donated vacation/no double taxation | 162 |
13 March 2014 External T.I. 2013-0510791E5 - Non-cash long-service award and cash donation
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11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder | 109 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder | 169 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 | 218 |
| Tax Topics - Income Tax Act - Section 9 - Timing | no s. 9(1) income inclusion from consultant being granted stock options until exercise | 216 |
| Tax Topics - General Concepts - Fair Market Value - Options | stock options with no in-the-money value could have nil FMV | 128 |
| Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) | s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares | 157 |
27 February 2014 External T.I. 2013-0506401E5 - Loan from a partnership to an individual
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) | partnership to partner shareholder loan | 63 |
15 November 2013 Internal T.I. 2013-0478621I7 F - Transfer of intangibles - TP adjustments
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| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | group sale with Canco not charging for intangibles should engage s. 247(2) | 141 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) | s. 69(4) inapplicable where grandchild Canco undercharges for asset sale, enhancing sales proceeds received by ultimate U.S. parent | 166 |
19 August 2013 External T.I. 2013-0488011E5 - Real Estate Referral Fees
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14 February 2013 Internal T.I. 2011-0424341I7 F - Amounts forwarded to trustee/beneficiary
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| Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) | s. 75(2) not applicable to dividends on common shares issued to discretionary family trust on estate freeze | 223 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | income was received by children beneficiaries as agent for their mother | 255 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) - Paragraph 104(6)(b) | Quebec discretionary trust with two named trustees but, in fact, only one trustee, would not be entitled to s. 104(6)(b) deductions | 151 |
9 January 2013 External T.I. 2010-0384221E5 F - Paiements indirects
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6 December 2012 External T.I. 2012-0461711E5 F - Paiements indirects / Indirect payments
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| Tax Topics - Income Tax Regulations - Regulation 200 - Subsection 200(1) | no T4A slip to be issued by producer paying mandatory contributions to the fund for the union of the artist whose corporation receives fees from the producer | 189 |
30 October 2012 Ontario CTF Roundtable, 2012-0462891C6 - Application of 56(2) to discretionary trust
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20 November 2012 Internal T.I. 2011-0416761I7 - Non-Resident, Part XIII Tax
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25 September 2012 BC Tax Conference Roundtable, 2012-0457551C6 - Application of 56(2) to discretionary trust
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Income Tax Technical News, No. 16, 8 March 1999
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1998 Strategy Institute Round Table, No. 981310
29 October 1996 T.I. 963032 (C.T.O. "Trustee Directing Payment or Right to Income")
30 October 1995 Internal T.I. 7-951631 -
2 June 1995 T.I. 950375 ("Charitable Gift Annuity in RRSP")
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| Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) | 27 |
2 November 1994 Memorandum 942044 (C.T.O. "Redirection of Salary During a Strike")
28 October 1994 T.I. 940246 (C.T.O. "Non-Capital Losses and Corp. Debt")
17 May 1993 Memorandum (Tax Window, No. 32, p. 2, ¶2592)
11 May 1994 Memorandum 932735 (C.T.O. "IAAC Payments Applied to a Loan after Bankrupt Discharged")
92 C.R. - Q.22
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 27 |
92 C.R. - Q.22
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 54 |
24 February 1992 Memorandum (Tax Window, No. 13, p. 12, ¶1628)
13 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 9, ¶1044)
23 March 1990 T.I. (August 1990 Access Letter)
14 July 1989 Inter-Divisional Memorandum (Dec. 89 Access Letter, ¶1045)
87 C.R. - Q.72
86 C.R. -Q.40
86 C.R. - Q.41
85 C.R. - Q.6
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | 13 |
84 C.R. - Q.24
84 C.R. - Q.82
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| Tax Topics - Income Tax Act - Section 67 | 54 |
81 C.R. - Q.26
79 C.R. - Q.19
IT-468R "Management or Administration Fees Paid to Non-Residents"
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| Tax Topics - Income Tax Act - Section 69 - Subsection 69(2) | 34 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 7 | 37 |
Articles
Bowman, "New Wine in Old Bottles - Using Personal Trusts as Business Vehicles", Business Vehicles, Vol. III, No. 1, 1996, p. 114
Beam, Laiken, "Recent Developments on Subsection 56(2): Indirect Payments", 1995 Canadian Tax Journal, Vol. 43, No. 2, p. 447.
Subsection 56(3) - Exemption for scholarships, fellowships, bursaries and prizes
See Also
Huang v. The Queen, 2012 DTC 1120 [at 3103], 2012 TCC 81 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) | 109 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(o) | 9 |
Subsection 56(3.1) - Limitations of scholarship exemption
Subsection 56(4) - Transfer of rights to income
Cases
Shaw v. The Queen, 89 DTC 5194 (FCTD), aff'd 93 DTC 5213 (FCA)
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| Tax Topics - General Concepts - Effective Date | 8 | |
| Tax Topics - General Concepts - Substance | 33 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 20 |
De Groote v. The Queen, 85 DTC 5008, [1985] 1 CTC 687 (FCTD)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 47 | |
| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | no longer beneficial shareholder | 74 |
Fraser Companies, Ltd. v. The Queen, 81 DTC 5051, [1981] CTC 61 (FCTD)
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The Queen v. Canadian-American Loan and Investment Corp. Ltd., 74 DTC 6104, [1974] CTC 101 (FCTD)
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| Tax Topics - General Concepts - Payment & Receipt | receipt of sums collected by affiliate | 143 |
The Queen v. Burns, 73 DTC 5219, [1973] CTC 264 (FCTD)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 60 |
See Also
Howard v. Commissioner of Taxation, [2014] HCA 21
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|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | damages not received as constructive trustee as not received qua director | 183 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | damages not corporate income as not received qua director | 183 |
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | agreement assigned rights to proceeds of law suit rather than entitlement under law suit | 305 |
Boutilier v. The Queen, 2007 DTC 479, 2007 TCC 96
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MFC Bancorp Ltd. v. The Queen, 99 DTC 905 (TCC)
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| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | largely overlapping boards of directors and substantial minority interest | 78 |
Ferrel v. The Queen, 97 DTC 1565 (TCC)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 132 |
Placements T.S. Inc. v. The Queen, 94 DTC 1302 (TCC)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 108 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 115 |
Sazio v. MNR, 69 DTC 5001 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 146 |
Administrative Policy
28 October 2016 External T.I. 2016-0654331E5 F - Transfer of rights to income
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| Tax Topics - Income Tax Act - Section 9 - Nature of Income | where rental lands purchased subject to obligation to pay the rents to vendor, rents did not have quality of income to purchaser under s. 9 | 159 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | where rental lands purchased subject to obligation to pay the rents to vendor, no income inclusion and deduction of the rents by the purchaser under ss. 9 and 18(1)(a) | 83 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | s. 56(2) could apply to shareholder of purchaser of lands if vendor did not pay FMV consideration for retaining rights to rents | 162 |
11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder | 109 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder | 164 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 | 218 |
| Tax Topics - Income Tax Act - Section 9 - Timing | no s. 9(1) income inclusion from consultant being granted stock options until exercise | 216 |
| Tax Topics - General Concepts - Fair Market Value - Options | stock options with no in-the-money value could have nil FMV | 128 |
| Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) | s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares | 157 |
10 July 2013 Internal T.I. 2013-0475501I7 F - Amounts returned to trustee/beneficiary
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| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | family trust income distributed to children but repaid as reimbursement to father for family expenses was income to him, not them | 199 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) | distributions to children immediately paid to father | 174 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) | distributions to children immediately paid to father were deductible even though received by children as his agents | 169 |
| Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | payment of income distributions by children to father not a benefit under the trust | 222 |
29 April 2003 External T.I. 2003-00646 -
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | 36 | |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1.1) | 36 |
8 September 1997 External T.I. 5-970715 -
3 February 1994 External T.I. 5-923647 -
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| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) | 19 |
3 December 1993 T.I. 920099 (C.T.O. "Transfer of Farm Inventory to a Corporation")
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| Tax Topics - General Concepts - Fair Market Value - Other | 64 |
Subsection 56(4.1) - Interest free or low interest loans
Administrative Policy
92 C.R. - Q.7
91 C.R. - Q.5
8 May 1990 T.I. (October 1990 Access Letter, ¶1461)
89 C.R. - Q.47
Articles
Joseph Frankovic, "Income Splitting and Attribution", Tax Topics, Wolters Kluwer, No. 2250, April 23, 2015
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| Tax Topics - Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (c) | 170 | |
| Tax Topics - Income Tax Act - Section 74.3 - Subsection 74.3(1) | 227 |
Emes, "Planning for Immigration to Canada from Countries other than the United States", 1993 Corporate Management Tax Conference Report, c. 13.
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| Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) | 4 |
Brahmst, "Subsection 56(4.1) - An Update", Canadian Current Tax, January 1992, p. P47.
Subsection 56(6)
Administrative Policy
14 May 2013 External T.I. 2013-0484971E5 F - PUGE - décès du conjoint
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(9.1) | deceased’s income did not include income on her rights and things return | 60 |
Subsection 56(9.1)
Administrative Policy
14 May 2013 External T.I. 2013-0484971E5 F - PUGE - décès du conjoint
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(6) | deceased had spouse at the end of her terminal year | 134 |
Subsection 56(12) - Foreign retirement arrangement
Cases
Serra v. Canada, 98 DTC 6602 (FCA)
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The Queen v. Arsenault, 96 DTC 6131 (FCA)
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| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 58 |
Administrative Policy
29 January 2018 External T.I. 2017-0682301E5 - Deemed Distribution and Withdrawal from IRA
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) - Clause 56(1)(a)(i)(C.1) | the deemed U.S. income inclusion from an IRA on renouncing U.S. citizenship or relinquishing a green card also is recognized for ITA purposes | 353 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | deemed Code taxability of IRA on renouncing U.S. citizenship generally would generate an FTC to deemed Cdn-resident recipient | 119 |