Canadian legal principles are applied in determining whether foreign taxes were paid on an agency basis for foreign tax credit purposes, so that...

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[T]he additional foreign taxes that are used in the year (in the form of an increase to the foreign tax credit for the year by means of section...

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The geographic source of employment is generally the physical place where the individual performs the related duties. Where this references more...

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1.53 While a determination of the place where a particular business (or a part of the business) is carried on (that is, the location of the...

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1.39 The appropriate share of the foreign taxes paid by a partnership of which the taxpayer is a member is considered to be tax paid by the...

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In determining the place where a business (or part of a business) is carried on (and, thus, the source of related business income for foreign tax...

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The evaluation of expected profitability is made over the entire period for which the property is expected to be held. S. 129(4.1) is not applied...

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Subject to any treaty provisions (e.g., Art. XXIV, para. 2(a) of the Canada-U.S. Convention), the foreign tax must be levied on net income (but...

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Subject to any treaty provisions (e.g., Art. XXIV, para. 2(a) of the Canada-U.S. Convention), the foreign tax must be levied on net income (but...

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S. 20(12) can provide a deduction to the extent the s. 126(1) proportionate limitation applies

1.24 If CTOP(FNBI) [Canadian tax otherwise payable...

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Provided that s. 4(3) is satisfied, "allocation of expenses to a source of gross income in a particular foreign country for financial statement...

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