Income Tax Act — I-3.3 153
 the tax payable under this Act by that person an amount equal to (a) in the case of dividends, 33 1/3% of the total amount of the dividends, (b) in the case of interest, 50% of the total amount of the interest, and (c) in the case of proceeds of disposition of property, 50% of the total of all amounts each of which is the amount, if any, by which the proceeds of disposition of a property exceed the total of any outlays and expenses made or incurred by the taxpayer for the purpose of disposing of the property (to the extent that those outlays and expenses were not deducted in computing the taxpayer’s income for any taxation year or attributable to any other property), except that no remittance under this subsection shall be required in respect of an amount that was included in computing the taxpayer’s income for the year or a preceding taxation year or in respect of an amount on which the tax under this subsection was previously remitted. Deemed effect of remittance (5) An amount remitted by a taxpayer under subsection 153(4) in respect of dividends, interest or proceeds of disposition of property shall be deemed (a) to have been received by the person beneficially entitled thereto; and (b) to have been deducted or withheld from the amount otherwise payable by the taxpayer to the person beneficially entitled thereto. Definitions (6) The following definitions apply in this section. designated financial institution means a corporation that (a) is a bank, other than an authorized foreign bank that is subject to the restrictions and requirements referred to in subsection 524(2) of the Bank Act ; (b) is authorized under the laws of Canada or a province to carry on the business of offering its services as a trustee to the public; or (c) is authorized under the laws of Canada or a province to accept deposits from the public and carries on the business of lending money on the security of real property or immovables or investing in indebtedness on the security of mortgages on real property or of hypothecs on immovables. ( institution financière désignée ) qualifying non-resident employee , at any time in respect of a payment referred to in paragraph (1)(a), means an employee who (a) is, at that time, resident in a country with which Canada has a tax treaty; (b) is not liable to tax under this Part in respect of the payment because of that treaty; and (c) works in Canada for less than 45 days in the calendar year that includes that time or is present in Canada for less than 90 days in any 12-month period that includes that time. ( employé non-résident admissible ) qualifying non-resident employer , at any time, means an employer (a) that at that time (i) in the case of an employer that is not a partnership, (A) is a resident of a country with which Canada has a tax treaty, or (B) is a corporation that does not satisfy the condition in clause (A), but would be a resident of a country with which Canada has a tax treaty if the corporation were treated, for the purpose of income taxation in that country, as a body corporate, and (ii) in the case of an employer that is a partnership, is a partnership in respect of which the total of all amounts, each of which is a share of the partnership’s income or loss for the fiscal period that includes that time of a member that, at that time, is a resident of a country with which Canada has a tax treaty (or is a corporation that satisfies the condition in clause (i)(B)), is not less than 90% of the income or loss of the partnership for the period (for the purposes of this subparagraph, where the income and loss of the partnership are nil for the period, the income of the partnership for the period is deemed to be $1,000,000); and (b) that is at that time certified by the Minister under subsection (7). ( employeur non-résident admissible ) Certification by Minister (7) The Minister may (a) certify an employer for a specified period of time if the employer has applied in prescribed form containing prescr