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2 September 1999 External T.I. 9816355- QUALIFIED SUBCHAPTER S SUBSIDIARY (QSSS)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 A qualified subchapter S subsidiary is a resident of the U.S. for purposes of the Canada U.S. Convention, given that the position of the Agency on the resident status of an S corporation has remained unchanged. ...

2004 IFA Roundtable Q. 3, 2004-007223-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Although a partner is not considered to own a specified percentage of the shares of a corporation held by a partnership, a favourable ruling was granted where a corporation issued sufficient voting preferred shares directly to each partner in order to comply with the formal requirements, of the Canada-U.S. Convention, Article X, para. 2(a), that the beneficial owner of the dividend must own at least 10% of the voting stock of the corporation paying the dividend. ...

Grantor Trusts-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 CRA indicated that if s. 94(3) applied to deem a US grantor trust with US-resident settlors to be a resident of Canada, then Art. IV(6) of the Canada-US Convention would not apply to dividends paid to the grantor trust by a Canadian corporation as both that corporation and the trust would be residents of Canada. ...

1 February 2012 External T.I. 2011-0431571E5- Canadian resource royalty received by US resident-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Oil royalty payments are covered by Art. VI, para. 2 of the Canada-US Convention ("amounts computed by reference to the amount or value of production from...resources") rather than by Art.XII, para. 4 ("payments...for...the use of...tangible personal property") and, accordingly, are not subject to the Treaty-reduced withholding tax rate. ...

1 February 2012 External T.I. 2011-0431571E5- Canadian resource royalty received by US resident-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 oil royalty payments are covered by Art. VI, para. 2 of the Canada-US Convention ("amounts computed by reference to the amount or value of production from...resources") rather than by Art.XII, para. 4 ("payments...for...the use of...tangible personal property") and, accordingly, are not subject to the Treaty-reduced withholding tax rate. ...

2003 Ruling 2003-0044063- Residency, France-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that Mr. X is a resident of France under the Canada-France Tax Convention given that he is liable to tax on worldwide income in France, his permanent home is in France (where his family now is), and his home in Canada is rented to arm's length third parties so that it is not available to him or his family. ...

24 March 2004 External T.I. 2003-0032781E5- Treaty benefits for Irish Investment Undertakings-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 An Irish Investment Undertaking would not be considered to be a resident of Ireland for purposes of the Canada-Ireland Convention given that it was not subject to comprehensive taxation in Ireland. ...

30 January 2002 External T.I. 2001-0106695- Subs. 219(5.3);Article X of Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 A deemed dividend under s. 219(5.3) of the Act will be treated as a dividend governed by Article X, paragraph 2 of the Canada-U.S. Convention, rather than paragraph 6, notwithstanding that such deemed dividend could be attributed to the decision not to pay branch tax pursuant to s. 219(5.1) at the time the non-resident insurance company incorporates the Canadian branch. ...

20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)-- summary under Rules Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27A- Rules A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to English estate duty to a deemed disposition under s. 70(5) on shares of a private Canadian corporation and would not be considered to be taxed in the U.K. by reference to an amount that was remitted to or received in the U.K. as a result of such deemed disposition. ... Convention would not apply. ...

20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to English estate duty to a deemed disposition under s. 70(5) on shares of a private Canadian corporation and would not be considered to be taxed in the U.K. by reference to an amount that was remitted to or received in the U.K. as a result of such deemed disposition. ... Convention would not apply. ...