Kevyn Nightingale, Amir Pourzakikhani, "A Federal Permanent Establishment, But Not a Provincial One", Tax Topics, Wolters Kluwer, November 3, 2016, No. 2330, p. 1

Summary Under
Tax Topics - Income Tax Act - Section 120 - Subsection 120(1)

U.S. resident with Cdn Services PE only (pp. 1-2)

We recently dealt with a situation where a non-resident individual taxpayer had a Permanent...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 4

CRA recently agreed with the position of a U.S.-resident individual who had a services permanent establishment in Canada under the Canada-U.S....

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