Subsection 105(1)
Cases
See Also
Beggs v. The Queen, 2016 TCC 11 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | refusal to grant Reg. 105 waiver not an assessment/remedy in Federal Court | 218 |
Stora Enso Beteiligungen GmbH v. The Queen, 2009 DTC 891, 2009 TCC 282
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Hamilton v. The Queen, 2007 DTC 121, 2006 TCC 603
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) | 64 |
Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation | narrow construction of Reg. so as to be intra vires | 188 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 | "in respect of" in Regulation read narrowly to conform with "for" in statute | 159 |
Ogden Palladium Services (Canada) Inc. v. The Queen, 2001 DTC 345 (TCC), briefly aff'd 2002 DTC 7378, 2002 FCA 336
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227 - Subsection 227(8) - Paragraph 227(8)(a) | due diligence defence not established in absence of evidence of professional advice | 249 |
Administrative Policy
27 November 2017 External T.I. 2017-0731441E5 - Interchange Canada and Business Number
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 102 - Subsection 102(1) | NR company seconding employee to Canada subject to Reg. 102 withholding requirement but not EI or CPP | 164 |
30 March 2017 Internal T.I. 2016-0636721I7 - Consent fees and withholdings
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(4) - Paragraph 212(4)(a) | consent fee was not for “advice or direction pertaining to the operation or administration of a company” | 153 |
| Tax Topics - Income Tax Act - Section 214 - Subsection 214(15) - Paragraph 214(15)(b) | whether consent fee was deemed to be interest under s. 212(15)(b) was moot | 116 |
9 September 2015 External T.I. 2014-0563611E5 F - Call Centre - Location of the services performed
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
12 February 2014 External T.I. 2013-0505511E5 - Cancellation fees paid to a non-resident artist
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
18 May 2012 IFA Roundtable, 2012-0444101C6 - non-resident withholding - services
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
28 November 2011 November CTF Roundtable, 2011-0426591C6 - Deemed services permanent establishment
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) | 206 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | subcontracting | 199 |
6 December 2011 External T.I. 2011-0405561E5 - Withholding on payment to non-resident
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
28 November 2010 CTF Roundtable Q. 9, 2010-0387091C6 - Late filing of T1 returns
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | 168 |
13 July 2001 Comfort Letter No. 20010713
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.3) | 58 |
7 December 1999 Miscellaneous 1999-0007810 - Application of subsection 17(2)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) | 55 |
7 August 1998 Discussion Paper on Proposed Changes to Revenue Canada's Guidelines for Treaty-Based Waivers of Regulation 105 Withholding (Draft)
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | 0 |
22 March 1995 T.I. 950463 (C.T.O. "Withholding Tax for Non-Resident Commuters (HAA 8019-1)")
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(1) - Paragraph 250(1)(a) | 43 |
8 July 1991 T.I. (Tax Window, No. 5, p. 22, ¶1339)
6 April 1990 T.I. (September 1990 Access Letter, ¶1441)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 79 |
1990 Answers Given by Scarborough District Office (May 1990 Access Letter, ¶1200, Q. 6)
12 November 1986 Press Release together with attachment entitled "Revised Administrative Policy - Non-Resident Withholding Taxes - Re: Services Rendered in Canada"
85 C.R. - Q.54
81 C.R. - Q.48
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 216 - Subsection 216(4) | Cdn lessee itself the agent | 35 |
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 102 - Subsection 102(1) | 0 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 10 |
Articles
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.