Section 81

Subsection 81(1) - Amounts not included in income

Paragraph 81(1)(a) - Statutory exemptions

Cases

The Queen v. AEL Microtel Ltd., 86 DTC 6348, [1986] 2 CTC 108 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) 78

Administrative Policy

26 August 2015 External T.I. 2015-0564171E5 F - Paiements d'un RPAC à un Indien

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.1) procedure for reduced withholding on pension distributions to status Indian 187

9 April 2013 External T.I. 2012-0461051E5 F - Employee of an international organization

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 8900 - Subsection 8900(1) - Paragraph 8900(1)(b) organization was not a specialized agency related to the UN 106
Tax Topics - Income Tax Act - Section 126 - Subsection 126(3) credit for local taxes imposed on salary of Canadian resident working for an international organization 231

9 January 2001 External T.I. 2000-005344 -

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Paragraph 81(1)(c) - Ship or aircraft of non-residents

Cases

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221

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Administrative Policy

24 December 2015 Internal T.I. 2014-0560831I7 - International shipping

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Words and Phrases
lease
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Shipping lease includes time charter 65

16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) application of Sutcliffe/Price allocation approach were s. 115(3) not applicable 140
Tax Topics - Income Tax Act - Section 115 - Subsection 115(4) non-resident's provision of crew and aircraft to Canadian airline 140
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Traffic non-resident's provision of crew and aircraft to Canadian airline 103
Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) Reg. 102 withholding or waiver notwithstanding Treaty exemption 162
Tax Topics - Treaties - Income Tax Conventions - Article 15 U.K company's provision of crew to Canadian airline/Reg. 102 withholding or waiver notwithstanding Treaty exemption 285

4 June 1996 T.I. 96 1114

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4 May 1995 T.I. 951182 (C.T.O. "Shipping Income - Residents of Greece")

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June 1992 Hong Kong Seminar (May 1993 Access Letter, p. 227)

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92 C.M.TC - Q.6

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2 July 1991 T.I. (Tax Window, No. 5, p. 15, ¶1326)

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Articles

Michael Shields, "Taxation of International Shipping Companies in Canada", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 1

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Owen, "Tax Issues in International Shipping", 1993 Canadian Tax Journal, Vol. 41, No. 4, p. 724.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 250 - Subsection 250(6) 0

Lang, "Taxation of International Aviation: A Canadian Perspective", 1992 Canadian Tax Journal, No. 4, p. 881.

Paragraph 81(1)(d) - Service pension, allowance or compensation

Administrative Policy

5 July 2013 Ministerial Correspondence 2013-0489561M4 - Taxation of the Veterans Independence Program

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Paragraph 81(1)(e) - War pensions

Administrative Policy

10 July 2014 External T.I. 2014-0529791E5 - Pension income arising in Hong Kong

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Paragraph 81(1)(g.1) - Income from personal injury award property

Administrative Policy

28 January 1992 Memorandum (Tax Window, No. 16, p. 17, ¶1723)

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Paragraph 81(1)(h) - Social assistance

See Also

Norton v. The Queen, 2009 DTC 1102 [at 558], 2008 TCC 91, aff'd 2010 DTC 5090 [at 6898], 2010 FCA 138

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Administrative Policy

19 March 1992 Memorandum (Tax Window, No. 18, p. 17, ¶1821)

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Paragraph 81(1)(e.2)

Subsection 81(2) - M.L.A.‘s expense allowance

Administrative Policy

83 C.P.T.J. - Q.24

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6 August 1992 T.I. 921792 (April 1993 Access Letter, p. 143, ¶C76-065)

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Subsection 81(3) - Municipal officers’ expense allowance

Cases

Bellrose v. Canada, 2012 DTC 5068 [at 6922], 2012 FCA 67

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Words and Phrases
municipality

Administrative Policy

26 June 1995 T.I. 950321 (C.T.O. "Municipal Officer's Expense Allowance")

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Subsection 81(3.1)