CRA publishes comment on beneficial ownership for Treaty purposes

CRA has published its response at the 2012 IFA Conference respecting when a recipient of interest, royalties etc. is the beneficial owner of those amounts for Treaty purposes.  It states that it "will generally accept that a payment will be for the recipient's use and enjoyment, and that the recipient assumes risk and control over the payment, if the recipient holds a sufficient degree of discretion with respect to the use or application of the payment."  This is similar to an earlier statement (see 2009 IFA Roundtable, Q.1 (No. 2009-0321451C6)).

Neal Armstrong.  Summary of 17 May 2012 IFA Round Table 2012-0444041C6 under Treaties - Art. 11.