5 November 1999 Internal T.I. 9827587 F - DÉDUCTION POUR IMPÔTS ÉTRANGERS -- attach -- Article 24
Art. XXIV(5)(b) of the Canada-U.S. Tax Convention, given that Art. XXIV(5)(b) applies to computing a tax credit rather than income from property
Article 24
11 April 2023 Internal T.I. 2023-0964101I7 - Tax issues for cross-border employees -- attach -- Article 24
FICA contributions of a cross-border employee are deductible only re employment income from duties physically performed in the US
3 February 2022 Internal T.I. 2021-0922301I7 - Art. XIII(7) Canada -US Treaty and Trusts -- attach -- Article 24
Art. XXIV(2)(a) of the U.S. Treaty does not require s. 126(1) to provide a carryback of US tax
Marin v. The Queen, 2022 TCC 49 -- attach -- Article 24
Art. 23 of French Treaty inapplicable where income of a particular taxation year was not otherwise taxed twice
9 July 2021 Internal T.I. 2021-0893981I7 - CERB received by non-residents -- attach -- Article 24
elimination of double taxation Art. addresses relief for taxation by Treaty partner of CERB payments
G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797 -- attach -- Article 24
UK would have been required to accord foreign tax credit to dual resident company if the US had imposed its taxes in accordance with the PE article
26 November 2020 STEP Roundtable Q. 4, 2020-0838001C6 - Foreign Tax Credit -- attach -- Article 24
a capital gain’s geographic source for Canadian FTC purposes was re-sourced to Australia under the Treaty-source rule
Nathan Boidman, "How Will Revised Sourcing Rules Affect Sales of U.S.-Made Goods Abroad?", Tax Notes International, 10 February 2020, p. 655 -- attach -- Article 24
3 December 2019 CTF Roundtable Q. 2, 2019-0824381C6 - Foreign taxes paid -- attach -- Article 24
US and UK Treaties do not eliminate FTC requirement that the taxes be paid
Zong v. The Queen, 2019 TCC 270 (Informal Procedure) -- attach -- Article 24
mandatory contributions by a dual resident to the UK’s national insurance scheme did not qualify for Treaty relief
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