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(Where any two of these three amounts are equal but less than the third amount, one of the amounts that are equal would be considered to be the least amount for this purpose; where all three amounts are equal, any one of the three amounts would be considered to be the least amount for this purpose.) ... Should a U.S. citizen resident in Canada claim to opt out of the Convention, any regular U.S. tax paid in excess of that required by the Convention is considered to be a voluntary tax. ... For example, if paragraph 3 of Article XI applies to exempt from U.S. taxation interest received by a resident of Canada, such interest would be considered to be Canadian source income for the purposes of the Convention. ...

(Where any two of these three amounts are equal but less than the third amount, one of the amounts that are equal would be considered to be the least amount for this purpose; where all three amounts are equal, any one of the three amounts would be considered to be the least amount for this purpose.) ... Pursuant to paragraph 6, for U.S. foreign tax credit purposes, an amount of $2,500 (i.e., $500 divided by the average tax rate of 20%) would be considered to be sourced to Canada. 3. ... Should a U.S. citizen resident in Canada claim to opt out of the Convention, any regular U.S. tax paid in excess of that required by the Convention is considered to be a voluntary tax. ...

In our view, any adjustment having to be made to the amount included to the taxpayer's income under paragraph 14(1)(b) pursuant to subsection 247(2) for the taxation year in which the disputed transaction occurred must be considered in determining the balance of the taxpayer's CDA at that time. ...

29 August 2014 Internal T.I. 2014-0534251I7- Indian Tax Exemption- Settlement Payments CRA Tags 81(1)(a) 104(2) 104(13) 75(2) 149(1)(c) Principal Issues: Whether federal settlement payments from a First Nation to its members would be considered income. ...

Position Adoptée: Yes Raisons: In these circumstances, the taxpayer would be considered to have made a misrepresentation that is attributable to wilful default (in French "omission volontaire"). ...

Neither the personal convenience of the taxpayer, nor the saving or deferment of income taxes would be considered a "sound business reason". ...

In order for subclause 46(2)(b)(v) to apply the corporation must be a party to a transaction or event before the beginning of the corporation's reference period and it may reasonably be considered that one of the main purposes of the transaction or event was to reduce or avoid the inclusion of a transitional tax debit or to increase the transitional tax credit. ...

Therefore the 1998 to 2008 years would be considered. The description of variable "Q" provides that the current year amounts under paragraph (a.1) of the definition "investment tax credit" are ignored. ...

However, by virtue of the "available for use rules" found in subsections 13(26) to (31) of the Act, CCA for a Class 43.1 or Class 43.2 property that has been acquired and which is not considered available for use at the end of a taxation year may be restricted until such time as the property is available for use. ...

For purposes of interpreting the Canada-XXXXXXXXXX Convention, the better view is to consider that the two Canadian partnerships are not separate persons with respect to the partners and the immovable property held by the intermediary of such partnerships should be considered as included in Canco's assets, according to its percentage of partnership interest. ...