Subsection 105(1)
Cases
See Also
Beggs v. The Queen, 2016 TCC 11 (Informal Procedure)
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| 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 | 244 |
Stora Enso Beteiligungen GmbH v. The Queen, 2009 DTC 891, 2009 TCC 282
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Hamilton v. The Queen, 2007 DTC 121, 2006 TCC 603
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) | 66 |
Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation | narrow construction of Reg. so as to be intra vires | 204 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 | "in respect of" in Regulation read narrowly to conform with "for" in statute | 169 |
Ogden Palladium Services (Canada) Inc. v. The Queen, 2001 DTC 345 (TCC), briefly aff'd 2002 DTC 7378, 2002 FCA 336
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Words and Phrases
services| 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 | 273 |
Administrative Policy
Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 26 June 2020
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 287 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | 191 | |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 129 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | 149 | |
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.1) | 239 | |
| Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) | comfort letters issued during COVID-19 | 36 |
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 | 173 |
| 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 | 138 |
| 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 | 170 |
30 March 2017 Internal T.I. 2016-0636721I7 - Consent fees and withholdings
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| 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” | 161 |
| 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 | 126 |
9 September 2015 External T.I. 2014-0563611E5 F - Call Centre - Location of the services performed
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12 February 2014 External T.I. 2013-0505511E5 - Cancellation fees paid to a non-resident artist
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18 May 2012 IFA Roundtable, 2012-0444101C6 - non-resident withholding - services
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28 November 2011 November CTF Roundtable, 2011-0426591C6 - Deemed services permanent establishment
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) | 214 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | subcontracting | 207 |
6 December 2011 External T.I. 2011-0405561E5 - Withholding on payment to non-resident
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28 November 2010 CTF Roundtable Q. 9, 2010-0387091C6 - Late filing of T1 returns
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | 176 |
24 August 2010 External T.I. 2010-0354791E5 F - Commission d'un non-résident - 105(1) RIR
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13 July 2001 Comfort Letter No. 20010713
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.3) | 58 |
7 December 1999 1999-0007810 - Application of subsection 17(2)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) | 57 |
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 External T.I. 9504635 - WITHHOLDING TAX FOR NON-RESIDENT COMMUTERS (HAA 8019-1)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(1) - Paragraph 250(1)(a) | 47 |
8 July 1991 T.I. (Tax Window, No. 5, p. 22, ¶1339)
6 April 1990 T.I. (September 1990 Access Letter, ¶1441)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 81 |
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
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| 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
Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42
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Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report
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