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3 September 1992 T.I. 920333 "Interest-Free Loans - Reason for Withholding" -- summary under Article 10

3 September 1992 T.I. 920333 "Interest-Free Loans- Reason for Withholding"-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 The word dividend in the Canada U.S. ...

6 January 1992 T.I. (Tax Window, No. 15, p. 14, ¶1679) -- summary under Article 7

(Tax Window, No. 15, p. 14, ¶1679)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Re taxability of rental payments derived from the use of moveable property in Canada by a Norwegian limited partnership. ...

16 February 1996 External T.I. 9512725 - PART XIII - PAYMENTS FOR RIGHT TO BROADCAST -- summary under Subparagraph 212(1)(d)(vi)

Convention. ...

25 March 1991 T.I. (Tax Window, No. 1, p. 9, ¶1166) -- summary under Article 5

(Tax Window, No. 1, p. 9, ¶1166)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Because the taxpayer's activities in Canada must be considered in relation to its business activities elsewhere, a U.S. resident will not be precluded from being considered to have a permanent establishment in Canada by virtue only of the Canadian activities having no expectation of profit. ...

28 June 1993 T.I. (Tax Window, No. 32, p. 6, ¶2598) -- summary under Article 5

(Tax Window, No. 32, p. 6, ¶2598)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A sales force in Canada could be regarded as stable or permanent activities of a U.S. corporation in Canada. ...

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152) -- summary under Article 21

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Re taxation of a U.S. charitable organization's share of dividends received by a U.S. partnership from a Canadian resident corporation. ...

12 September 89 T.I. (February 1990 Access Letter, ¶1124) -- summary under Section 255

(February 1990 Access Letter, ¶1124)-- summary under Section 255 Summary Under Tax Topics- Income Tax Act- Section 255 Neither section 255 of the Act, nor section 5 of the Income Tax Conventions Interpretation Act, are relevant to the interpretation of the "in Canada" requirement in s. 127(9). ...

14 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 4, ¶1047) -- summary under Article 4

No. 2, p. 4, ¶1047)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 In the case of a corporation incorporated in Canada and having its place of effective management in The Netherlands, Canada will not agree that the corporation is a resident of The Netherlands in the absence of evidence that Canadian tax is not being avoided. ...

T.I. 921585 (December 1992 Access Letter, p. 24, ¶C111-048) -- summary under Article 19

T.I. 921585 (December 1992 Access Letter, p. 24, ¶C111-048)-- summary under Article 19 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 19 A Canadian citizen who is employed at the Canadian embassy in Washington will be subject to tax in Canada even after he has acquired U.S. citizenship. ...

2006 Ruling 2004-0106101R3 - Class of German Arrangement & Treaty Benefits -- summary under Article 4

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that a German open-end real estate fund would be treated as a resident of Germany for purposes of Article 4 of the German Treaty. ...

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