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...
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...
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...
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...