Words and Phrases - "credit"
19 November 2019 Roundtable, 2019-0829611C6 - TEI 2019 Conference Question E1- Pays or Credits
In response to questions as to how a Canadian corporation may recover Part XIII tax that it has withheld on a dividend cheque issued to a US...
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Tax Topics - Income Tax Act - Section 212 - Subsection 212(2) | meaning of crediting a dividend | 193 |
19 November 2019 Roundtable, 2019-0829611C6 - TEI 2019 Conference Question E1- Pays or Credits
In response to questions as to how a Canadian corporation may recover Part XIII tax that it has withheld on a dividend cheque issued to a US...
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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) | IC 77-16R4 meaning of “credited” confirmed | 193 |
Vega International Car Transport and Logistic — Trading GmbH v. Dyrektor Izby Skarbowej w Warszawie, ECLI:EU:C:2019:412 (European Court of Justice, 8th Chamber)
The business of the subsidiaries of Vega International included the transport of commercial vehicles from the manufacturer to customer....
North Shore Power Group Inc. v. Canada, 2018 FCA 9
The appellant (“North Shore”) entered into contracts in 2010 with Menova Energy Inc. for the purchase of solar panels, under which it paid...
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Tax Topics - Excise Tax Act - Section 231 - Subsection 231(1) | no bad debt credit under s. 231 for a s. 232 credit which becomes bad | 157 |
14 July 2015 External T.I. 2013-0499621E5 - Paragraph 212(1)(d) and Credited
A royalty charged by a U.S. resident (the "Licensor") to a corporation resident in Canada (the "Taxpayer") was, in lieu of payment by the Taxpayer...
Canada v. Gillette Canada Inc., 2003 DTC 5078, 2003 FCA 22
Some of the shares held by the taxpayer in its French subsidiary were purchased for cancellation by the subsidiary in consideration for the...
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Tax Topics - General Concepts - Payment & Receipt | replacement with different currency note | 60 |
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) | 150 |
Richard Lewin Re: The J.J. Herbert Family Trust #1 v. The Queen, 2011 DTC 1354 [at at 1979], 2011 TCC 476, aff'd 2013 DTC 5006 [at 5525], 2012 FCA 279 [but overridden by s. 214(3)(f)(i)(C)]
The taxpayer was a trustee for a family trust, which received a dividend in 2001 of over $2 million. The trust adopted an unconditional...
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Tax Topics - Income Tax Act - Section 227 - Subsection 227(5) | 167 | |
Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius | 144 |
La Compagnie Minière Québec Cartier v. M.N.R., 84 DTC 1348, [1984] CTC 2408 (TCC)
The taxpayer received demand loans from its U.S. parent which provided for the semi-annual payment of interest but provided that the taxpayer, on...