Principal Issues: 1) Whether an employee meets the conditions of paragraph 6(16)(a); 2) Whether the full value of transportation benefits provided may be excluded from the employee's income.
Position: 1) Question of fact. 2) Question of fact, likely yes.
a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. IV(6) for the 5% Treaty-reduced rate on dividends to its U.S. parent
a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. IV(6) for the 5% Treaty-reduced rate on dividends to its U.S. parent
Submitted by narmstrong on Mon, 12/09/2019 - 04:17
a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. IV(6) for the 5% Treaty-reduced rate on dividends to its U.S. parent
Parentco, a corporation resident in the U.S. for Treaty purposes, is the only member of Parentco LLC, which is the only member of Sisterco LLC,...
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secondary adjustment benefit to a NR sister was a dividend for Treaty purposes
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Principal Issues: (1) whether a deemed dividend under subsection 247(12) is a dividend for purposes of Article X; (2) whether paragraphs IV(6) and (7) of the Canada-US Income Tax Convention would apply to a deemed dividend under subsection 247(12).
