Article 21 - Exempt Organizations

Cases

Chua v. MNR, 2001 DTC 5104 (FCTD)

McKeown J. issued an order (with which counsel for the Minister was in agreement) that would permit Parliament two years in which to provide new...

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See Also

Emballages Starflex Inc. v. ARC, 2015 QCCQ 7455 (Cour du Québec)

The taxpayer, which derived much of its income from sales to the U.S., donated $493,000 to U.S. charities which were not Canadian registered...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose claiming a charitable deduction inconsistent with treating same outlay as a business expense 143

Administrative Policy

25 August 2021 External T.I. 2020-0866131E5 - Gifts by Will

Will a bequest made by will to a U.S. organization qualify for a charitable donation credit on the individual’s final return? CRA summarized...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts - Paragraph (c) carryback to terminal return of gift made by will to a US charity 360

17 November 2015 Roundtable, 2015-0614251C6 - 2015 TEI Meeting Q7 Donations to qualifying US charity

(a) A gift made by a Canadian-resident corporation to a U.S. resident charity described in Art. XXI, para.7 of the Canada-U.S. Treaty is...

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5 October 2012 Roundtable, 2012-0451231C6 F - Gifts to American charities

Does Art. XXI, para. 7 of the Canada-U.S. Convention allow charitable foundations as defined in s. 149.1(1) to make donations to U.S. charitable...

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2007 Ruling 2005-0149681R3 - Article XXI of Canada-US Tax Convention

Activities undertaken in Canada, including through leased premises, that related primarily to fund raising would not constitute a business of the...

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15 March 2006 External T.I. 2005-0124911E5 F - Prestation compensatoire française

CRA found that a lump sum paid in two instalments paid as a “compensatory allowance” under French law by a French-resident ex-spouse of the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount life annuity, but not lump sum, received from divorced ex-spouse in France as “compensatory allowances” under the French Civil Code was taxable as support 166
Tax Topics - Treaties - Income Tax Conventions - Article 18 life annuity, was to be treated for Treaty purposes as alimony or similar payments since it was treated by CRA as a support amount under ITA 210
Tax Topics - Treaties - Income Tax Conventions - Article 3 treatment of a life annuity under ITA, as a support amount meant that it was to be treated for Treaty purposes as alimony or similar payments 136

12 April 1999 9812726 - ARTICLE XXI CANADA-U.S. (4125-U5-100-21)

Before any consideration could be given to allowing an exemption for investment income paid to a U.S. master trust, the trust would be required to...

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17 February 1997 External T.I. 9625935 - SOURCE OF CANADIAN TRUST INCOME RE ART XXI(6)

Where a trust resident in Canada has made a designation under s. 104(22) with respect to U.S.-source income earned by the trust and distributed to...

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1996 Corporate Management Tax Conference Tax Conference Round Table Q. 21

In the context of Article XXI of the Canada-U.S. Convention, "related person" has the meaning assigned in the Act.

"Where a person is a member of...

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15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)

Re taxation of a U.S. charitable organization's share of dividends received by a U.S. partnership from a Canadian resident corporation.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 22 19

25 April 1991 T.I. (Tax Window, No. 2, p. 28, ¶1216)

Exempt organizations created in a country with which Canada has a tax treaty are residents of that contracting state for treaty purposes and are...

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25 March 1991 T.I. (Tax Window, No. 1, p. 18, ¶1169)

Where a tax-exempt organization is a member of a partnership which has been subject to Part XIII tax on income payments received by it, RC on...

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87 C.R. - Q.3

a U.S. pension trust or charitable trust is entitled to the exemption provided in paragraph 2 of Article XXI of the Canada-U.S. Income Tax...

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