Subsection 104(2)
Administrative Policy
17 December 2018 Internal T.I. 2016-0659031I7 F - Attendance of board of directors meeting by phone
After indicating that the participation in Canadian board meetings by telephone from outside Canada would generally not constitute the exercise of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | participation in Canadian board meetings by telephone from outside Canada is not the exercise of the office in Canada | 109 |
13 March 2023 External T.I. 2022-0947251E5 - Withholding on Payment to Non-Resident Employees
A resident Canadian corporation pays to its only employee (who ceased to be resident in a previous year) monthly remuneration (subject to income...
9 March 2017 External T.I. 2016-0677351E5 - Withholding on remuneration paid to a non-resident
A corporation resident in Canada pays salary and director’s fees to a shareholder who is U.S.- resident individual, who is not in Canada in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 200 - Subsection 200(1) | Reg. 104(2) exemption does not apply for T4 reporting purposes, subject to $500 exclusion | 165 |
17 June 2008 Internal T.I. 2008-0276721I7 - Withholding requirements for non-resident employee
A Canadian-resident non-profit corporation which was a post-secondary educational institution (the "College") established a campus in a country...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 200 - Subsection 200(1) | Canadian college with non-Treaty country "business" campus | 101 |
7 December 2012 External T.I. 2012-0440411E5 F - Performing services in Canada
A Quebec employer carries on an information systems business in Quebec using a server in Quebec and employs a non-resident programmer-analyst who...
14 November 2007 External T.I. 2007-0245631E5 F - Retenue à la source -employé à l'étranger
A French national was employed by a Canadian corporation since August 1998 and resided in Canada from that date until July 29, 2007, when he...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(c) | employment for Canadian employer exercised in France and not exempt from French tax was not deemed to be exercised in Canada | 152 |
"Non-Residents Performing Services in Canada - An Update on Withholding Tax and Permanent Establishment Issues, Toronto Centre CRA and Professionals Consultation Group Breakfast Seminar, June 15, 2005, Q.3 - Director's Fees"
Articles
Ron Choudhury, "An Overlooked Solution for Non-resident Employers", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24 No. 7, September 2015, p. 1643.
Allocation of payroll of non-resident employee performing in Canada (p. 1646)
[C]anadian payroll deductions will be required when a non-resident...
Paragraph 104(2)(b)
Administrative Policy
3 May 2005 Internal T.I. 2005-0120711I7 F - Subsection 104(2) of Regulations
Would Reg.104(2)(b) apply to a lump sum payment of a retiring allowance by a Canadian employer to a former employee who is not resident in Canada...