Subsection 270(1)
Active NFE
Paragraph (a)
Administrative Policy
Guidance on the Common Reporting Standard, Part XIX of the Income Tax Act, 19 December 2025
Relevance of active/ passive NFE distinction
4.3 There are two types of NFEs: active and passive. The distinction is important since a reporting...
Canadian Financial Institution
Paragraph (a)
Administrative Policy
Guidance on the Common Reporting Standard, Part XIX of the Income Tax Act, 19 December 2025
Residence of partnership
3.32 A Canadian financial institution can take the form of a partnership. A partnership will be considered as a Canadian...
Controlling Persons
Administrative Policy
29 November 2022 CTF Roundtable Q. 10, 2022-0950581C6 - Common Reporting Standard
Where a resident trust (other than a “reporting financial institution” (RFI), is a “passive non-financial entity” (Passive NFE), and has a...
Paragraph (a)
Administrative Policy
10 June 2025 Internal T.I. 2023-0970361I7 - Interpretation of “controlling persons” definition
Trust B, a Canadian resident discretionary trust, was the only beneficiary of Trust A, also a Canadian resident discretionary trust. Both trusts...
Investment Entity
Administrative Policy
Guidance on the Common Reporting Standard, Part XIX of the Income Tax Act, 19 December 2025
CIV (but not a REIT) is generally considered an investment entity
3.21 An entity is generally considered an investment entity if it functions or...
Reportable Jurisdiction Person
Articles
Robert E. Ward, "The Common Reporting Standard Comes to Canada", Tax Management International Journal, Vol. 46, No. 9, 8 September 2017, p. 538
Evasion of FATCA and CRS reporting (p. 540)
Perhaps the greatest commonality between CRS and FATCA is the ease with which both regimes may be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 271 - Subsection 271(1) | 138 |