Subsection 100(1)
Remuneration
See Also
Coopers & Lybrand Limitéé v. MNR, 94 D.T.C 1626 (TCC)
The appellant took possession on November 4, 1981 of the business of a debtor and, with the banks' authorization, paid the net amount of the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.3) | 165 |
Administrative Policy
24 September 2015 External T.I. 2013-0495611E5 - Withholding on incentive payments to non-residents
A Canadian resident manufacturing corporation ("Canco") pays the non-resident employees ("Dealer Employees"), of non-resident dealers selling its...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(iii) | no withholding on payments based on sales warranties sold by dealers | 126 |
| Tax Topics - Income Tax Regulations - Regulation 200 - Subsection 200(1) | T4A reporting of payments to non-resident employee of 3rd party | 84 |
13 June 2003 TI
Where a lawyer, who is a member of a professional partnership, is a director of a corporation, the director's fees paid to him will not be subject...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(g) | 42 |
8 October 1996 T.I. 962701 (C.T.O. "Loss of Employment, Mental Distress, Damages")
Reimbursements of the legal fees incurred in a wrongful dismissal action are not "remuneration".
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | 111 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(l.1) | 65 |
18 June 1993 T.I. (Tax Window, No. 32, p. 10, ¶2603)
A plan under which sick leave benefits to which an employee is entitled under the terms of an employment contract or collective agreement are paid...
4 February 1993 Memorandum (Tax Window, No. 29, p.18, ¶2425)
Payments made by an employer to an employee profit sharing plan are subject to source deductions.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | 28 |
Ladd, "Verification and Collection Issues", 83 C.R., p. 771
Although RC's position is that "payment" is to be read in a broader context than a mere exchange of cash, RC recognizes that it would be...
Subsection 100(4)
Administrative Policy
21 July 1992 Memorandum 921453 (January - February 1993 Access Letter, p. 34, ¶C144-197)
An establishment of an employer would have many of the same characteristics as that of a permanent establishment, as defined in Regulation 400(2).
14 May 1991 T.I. (Tax Window, No. 3, p. 10, ¶1237)
Where a U.S. corporation sends its employees to a Canadian subsidiary for work assignments, and the employees report for work at the Canadian...
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|---|---|---|
| Tax Topics - Treaties - Article 5 | 64 |