Administrative Policy
2015 Ruling 2014-0542411R3 - Carrying on business in Canada and PE
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | PE in Canada of ForCo avoided through seconding employees to its Cdn sister and meeting in Canada up to 90 days annually only offsite | 513 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | seconded employees respected as employees notwithstanding their payroll is paid by (and reimbursed to) ForCo | 57 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | no mark-up on cross-border payroll reimbursement represented to accord with s. 247 | 101 |
Subsection 102(1)
Administrative Policy
27 November 2017 External T.I. 2017-0731441E5 - Interchange Canada and Business Number
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) | a non-resident corporation is carrying on business in Canada by virtue of being the legal employer of an employee seconded to Canada | 163 |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | NR corp carrying on business in Canada by virtue of being reimbursed for payroll costs of seconded employee | 130 |
| Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) | salary reimbursement payments made to seconding NR employer subject to withholding | 107 |
4 February 2016 Internal T.I. 2015-0620821I7 F - Withholding of income tax at source
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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 Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) | non-resident's provision of crew and aircraft to Canadian airline | 103 |
| 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 |
22 March 2012 Internal T.I. 2012-0436311I7 - payroll withholdings by non-resident employer
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7 December 1999 Miscellaneous 1999-0007810 - Application of subsection 17(2)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) | 55 |
IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) | 0 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 10 |
Articles
Anu Nijhawan, "Source Withholdings: Non Resident Employees 'Visiting' Canada", Taxation of Executive Compensation and Retirement, Vol. 15, No. 9, May 2004, p. 412.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.1) | 0 |