Regulation 403

Subsection 403(3)

Administrative Policy

8 June 2018 Internal T.I. 2018-0744881I7 - Regulation 403 – allocation of income

An insurance corporation (that reinsures policies issued by another insurer) holds partnership interests in several partnerships that have no...

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Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(1) a partner is attributed each PE of a partnership for Reg. 400(1) purposes 230

Subsection 403(4)

Administrative Policy

24 October 2018 Internal T.I. 2018-0741041I7 - Allocation of net premiums under s. 403(4)

The taxpayer, a Canadian property insurer insures risk inside and outside Canada, but has no permanent establishment (“PE”) outside Canada....

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reasonably attributable

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