Subsection 2601(1)
Administrative Policy
22 February 2002 Internal T.I. 2001-0095217 F - FAILLITE-PROVINCE DE RESIDENCE
An individual resided in a province at the time of becoming a bankrupt (thereby causing a short taxation year pursuant to s. 128(2)(d)) and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 128 - Subsection 128(2) - Paragraph 128(2)(e) | returns for both stub returns for year of bankruptcy are filed for the province of the individual’s residence on December 31 of that calendar year | 76 |
7 October 2011 Roundtable, 2011-0411911C6 F - Exploitation entreprise par SP
To the extent that a Quebec partnership does not carry on business, is the property income earned by it taxable only in each partner's province of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | Quebec partnership need not carry on business | 188 |
4 April 2002 External T.I. 2001-0104065 F - PROVISION D'ENTREPRISE DANS UNE PROVINCE
An individual left a Quebec partnership in 1998 to take up employment in Ontario and ceased to have any connection to it or any other source of...
26 October 1989 Memorandum (March 1990 Access Letter, ¶1152)
Individuals who do not carry on business in Canada and who are not actually resident in Canada but who are deemed resident in Canada under the...
Articles
H. Michael Dolson, "Trust Residence After Garron: Provincial Considerations", Canadian Tax Journal, (2014) 62:3, 671-99.
Structuring so that decisions are made in a different jurisdiction (pp. 692-3)
Once the identity of the person who has central management and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 108 |
Subsection 2601(2)
Cases
Hollinger v. M.N.R., 73 D.T.C. 5003, [1972] C.T.C. 592 (FCTD)
The taxpayer was an individual resident in Quebec who took the position that her share of income earned by a New Jersey partnership engaged in...
Administrative Policy
28 September 2020 External T.I. 2019-0800551E5 - Provincial Residency of a TFSA Trust
When asked where a self-directed TFSA was resident, CRA indicated that the trust would always be resident where its central management and control...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | central management and control of a TFSA trust is generally exercised in the office of the investment firm to which most of the trustee’s functions have been delegated | 325 |
| Tax Topics - Income Tax Regulations - Regulation 2600 - Subsection 2600(2) | office of investment manager of TFSA treated as a PE of the TFSA | 343 |