Regulation 402.1

Administrative Policy

Income Tax Technical News No. 44, 14 April 2011

Can CRA comment on the “reasonably be expected” test where the corporation that is the recipient of the services has never performed the...

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Articles

Brian Robson, "Provincial Income Allocation", Canadian Tax Highlights, Vol. 24, No. 8, August 2016, p. 3

Only applies if paymaster corp's employees spend 90% of their time on the related corp's activity (p. 3)

The central-paymaster provision in...

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Subsection 402.1(1)

Subsection 402.1(3)

Subsection 402.1(5)

Administrative Policy

2 February 2018 Internal T.I. 2017-0728331I7 - Central paymaster - partnership

A partnership is the legal employer, with Corp 1 having a 30% partnership interest, and Corp 2 having a 70% partnership interest. The corporation...

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Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(6) exclusion from payroll allocated to partners for Reg.402(6) 174

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