CRA confirms that a non-Treaty company potentially can qualify for Treaty benefits “through” a U.S. partnership

CRA has published its position that a company which is resident in a non-Treaty country (e.g., the Caymans) nonetheless may qualify for the branch profits reduction under Art. X(6) of the Canada-U.S. Convention on its share of Canadian branch profits of a U.S. partnership that has elected to be a domestic corporation for Code purposes, if those profits qualify as connected to a substantial U.S. active business under Art. XXIX-A(6).

Neal Armstrong.  Summary of 17 May 2012 IFA Round Table "Branch Tax Rate" 2012-0444151C6 under Treaties – Art. 10.