Subsection 201(1)
Administrative Policy
15 August 2014 External T.I. 2014-0532941E5 - T5 reporting obligations
Opco has issued the "Debentures" in fully registered form to the resident "Brokers," who then sold them to their resident "Clients" for whom they...
T4015(E) "T5 Guide - Return of Investment Income 2013"
If the payment is made to the registered holder of an investment (for example, broker or trustee of an RRSP), enter the name of the registered...
Paragraph 201(1)(a)
Administrative Policy
3 March 2011 External T.I. 2010-0381851E5 F - Ajustements salariaux rétroactifs
After finding that retroactive salary adjustments paid for a nine-year period were not eligible for treatment under the averaging rules in ss....
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Qualifying Amount - Paragraph (a) - Subparagraph (a)(i) | retroactive pay adjustments negotiated to comply with the Quebec Pay Equity Act but not paid pursuant to it were not qualifying amounts | 203 |
24 October 2017 External T.I. 2016-0653441E5 - U.S. Dividend Equivalent Amounts
What are the Canadian tax reporting requirements respecting a payment made under a Canadian financial contract (i.e. a contract between an entity...
Subsection 201(4.1)
Administrative Policy
22 December 2003 External T.I. 2003-0000125 F - TITRE DE CREANCE INDEXE
CCRA noted that statements in the T5 Guide - Return of Investment Income to the effect that:
- It will treat as interest any increase or decrease...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Regulations - Regulation 7001 - Subsection 7001(1) | detailed illustration | 15 |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Indexed Debt Obligation | stripped indexed coupons were indexed debt obligations but would not give rise to excluded payments | 34 |
Tax Topics - Income Tax Regulations - Regulation 7001 - Subsection 7001(7) - Excluded Payment | stripped indexed coupons did not give rise to excluded payments because no single fixed rate | 52 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(14) | application of s. 20(14) to indexed debt obligation | 143 |
Subsection 201(2)
Administrative Policy
2 March 2001 External T.I. 2001-0069555 F - Dividendes - (U.S. spin-off)
In the context of discussing the potential application of the proposed s. 86.1 rules to a spin-off distribution by a US public corporation, CCRA...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 86.1 - Subsection 86.1(2) | detailed review of proposed s. 86.1 | 110 |
90 C.R. - Q23
Regulation 201(2) is considered to apply in the situation where a law firm holds funds received from its client in trust pending application of...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) | 59 |
Subsection 201(4)
Administrative Policy
19 June 2014 External T.I. 2014-0519881E5 - T5 reporting requirements
In Year 1, Canco issued unsecured convertible Debentures bearing interest that is payable only on maturity one year later in Year 2. In finding...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | debenture with interest payable on 1-year maturity not an investment contract | 161 |
12 October 2010 External T.I. 2010-0371931E5 F - T5 Information Returns
As a result of some of the coupons on a bond having been detached from a bond that was acquired on January 1, 20X0 by a resident of Canada, the...
28 July 1994 940615 (C.T.O. "T-5 Reporting")
In response to a query as to whether T-5 reporting was required for a stock-index linked obligation on which a contingent payment was based on the...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) | 72 |
Articles
Ulmer, "Taxation of Interest Income", 1990 Conference Report, c. 8.
Subsection 201(6)
Administrative Policy
Handbook on Securities Transactions, 94-110(E)
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) | 26 |