29 August 1989 External T.I. 89M08020 F - Reporting of Amounts Paid/Credited to Non-residents

By services, 18 January, 2022
Official title
Reporting of Amounts Paid/Credited to Non-residents
Language
French
CRA tags
212(1), 212(5)
Document number
Citation name
89M08020
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633176
Extra import data
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"field_release_date_new": "1989-08-29 08:00:00",
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Main text
  August 29, 1989
TO - Non Resident Taxation Division FROM - Technical 
Source Deductions Section Interpretations Division
  Phil K. Tang
ATTN: Gary Richardson (613) 957-9229
Program Officer

SUBJECT: REPORTING OF AMOUNTS PAID/CREDITED TO NON-RESIDENTS

At your request, we have reviewed the "Income Codes" page in the draft Non-Resident Tax Information Package and have the following comments:

1.      There seems no discussion of payment or credit for "Timber royalties" (paragraph 212(1)(e) of the Act).

2.      Item 21: We suggest deleting "copyrights" in this item since subsection 212(5) refers specifically only to the right in or to the use of motion picture film or videotape and other means of reproduction for use in connection with television.  It may then read "Motion pictures, TV films or videotapes, etc."

3.     Item 28: It may be unclear whether royalties for the use of R & D property is included here or under item 31.

4.     Item 30: We suggest deleting the word "payment" (see paragraph 212(1)(j)).

5.      Item 31: We suggest replacing "Royalties-Other" by "Royalties and similar payments for the use of or for the right to use other properties" to cover other payments described in paragraph 212(1)(d) of the Act but not mentioned in these codes.

We trust our comments will be of assistance.

A.G. Cockell, DirectorTechnical Interpretations DivisionLegislative and IntergovernmentalAffairs Branch