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...
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...
Subsection 402.1(1)
Administrative Policy
Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024
Non-application of central paymaster rule to admin services
2.66 Generally, the central paymaster rules would not apply in a situation where the...
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(6) | exclusion from payroll allocated to partners for Reg.402(6) | 174 |