Paragraph 250.1(a)
Cases
Marino v. Canada, 2022 FCA 115
An individual with no connection to Canada paid significant tuition fees while in attendance at U.S. universities prior to 2012 then, on...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxation Year | Oceanspan principle indicates that a non-resident who does not compute income from any source for ITA purposes does not have a taxation year | 264 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | s. 104(13) requirement to compute the income of a non-resident trust with a Canadian beneficiary is an example of s. 250.1(a) application | 284 |
See Also
Marino v. The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115
An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(b) | tuition paid prior to becoming subject to tax under Part I was not to be recognized under s. 118.5(1)(b) | 455 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer | an individual not within s. 2(1) or (3) was not a taxpayer who could generate a tuition tax credit | 293 |
Paragraph 250.1(b)
Administrative Policy
2 October 2012 External T.I. 2012-0448021E5 - Distribution by a non-resident trust
Given that "[p]aragraph 250.1(b) of the Act generally provides that where income is to be determined under the Act for a non-resident person, it...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | income of non-resident trust determined under ITA principles (inclusion of 1/2 capital gains) | 107 |