Michael Lang, "Income Allocation Issues Under Tax Treaties", Tax Notes International, April 21, 2014, p. 285.

No implications of specific safe harbours (p. 287)

Therefore, a special provision is no indication that something else applies outside its...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Allocation conflict in Sommerer (pp. 289-90)

[S]ubsection 75(2)…is an allocation rule that can lead to the income being taxed in the hands of a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.