Regulation 105

Subsection 105(1)

Cases

FMC Technologies Co. v. Canada (National Revenue), 2008 DTC 6560, 2008 FC 871

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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 218

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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Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65

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Words and Phrases
for in respect of retainer fee
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

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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 249

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 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

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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” 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

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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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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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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 Miscellaneous 1999-0007810 - Application of subsection 17(2)

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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)")

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8 July 1991 T.I. (Tax Window, No. 5, p. 22, ¶1339)

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6 April 1990 T.I. (September 1990 Access Letter, ¶1441)

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1990 Answers Given by Scarborough District Office (May 1990 Access Letter, ¶1200, Q. 6)

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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

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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"

Articles

Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report

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Elaine Marchand, Florie Pellerin-Catellier, "Foreign Service Providers in Canada and Regulation 105", 21 Canadian Current Tax, Vol. 21, No. 2, November 2010, p. 21.

Jules Lewy, "Withholding Requirements for Non-Resident Service Providers in Canada", Tax Notes International, 7 June 2004, p. 1079.

Shannon Baker, Dale Meister, "Non-Residents Rendering Services In Canada: Regulation 105 and Other Issues", International Tax Planning, 1999 Canadian Tax Journal, Vol. 47, No. 5, p. 1321.

Albert Baker, Mark Briggs, "Revenue Canada Provides Increased Guidance on Waivers from Withholding under Regulation 105", International Tax Planning, Vol. VIII, No. 4, p. 596.

Murray, "Computer Software: Canadian Cross-Border Issues", 1993 Conference Report, C. 27

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Scheuermann, "Income and Commodity Tax Aspects of Acquiring and Exploiting Technology", 1991 Conference Report, c. 45.

Bacal, Lewin, "The Taxation in Canada of Non-resident Performing Artists and Behind-the-Camera Personnel", Canadian Tax Journal, November-December 1986, p. 1287

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