Subsection 217.1(1)
Administrative Policy
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"
Non-resident trust (majority Cdn-owned) with Cdn activity and no Cdn PE
Example 5
A non-resident mutual fund trust has a non-resident trustee. The...
Articles
Alan Kenigsberg, "Changes to Tax Treatment of ILPs under the ETA", Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9
Aborted proposal to extend qualifying taxpayer rules to non-resident LPs (p. 12)
When the Department of Finance first announced that it was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Investment Limited Partnership | 259 | |
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(8) | 52 |
Paragraph 217.1(1)(b)
Administrative Policy
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"
Ss. 132(2) and (3) rules do not apply for purposes of s. 217.1(1)(b)(i)
Qualifying taxpayer
…
The reference to being resident in Canada in the...
Subsection 217.1(2)
Paragraph 217.1(2)(a)
Administrative Policy
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"
Canco deductions for parent head office expenses are included
Examples - Qualifying consideration - Part A
Example 1
A non-resident FI has its...
Paragraph 217.1(2)(d)
Administrative Policy
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"
Scope of s. 217.1(2)(d)
As a result, in the case of a resident qualifying taxpayer, if an employee performs duties outside Canada and a...
Subsection 217.1(4)
Administrative Policy
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"
Example of internal charge
A qualifying taxpayer resident in Canada has made an election under subsection 217.2(1) to self‑assess on the total...