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20 February 2003 External T.I. 2002-014360-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 A s. 20(12) deduction may not be taken by a U.S. citizen resident in Canada on the withholding from U.S. source property income that is in excess of a rate of 10% and less than a 15% rate. ...

LLPs and LLLPs-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Florida and Delaware LLPs and LLLPs treated like LLCs Are Florida and Delaware LLPs and LLLPs that are treated by CRA as corporations considered to come within para. ...

13 November 2009 Internal T.I. 2009-0318491I7- Article IV(6)/IV(7) 'Same Treatment'-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 interest paid by ULC to its U.S. corporate shareholders is not subject to IV(7)(b) if the ULC is a partnership for Code purposes ...

21 December 2009 External T.I. 2009-0330491E5- Article XXI Exemption-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 IV(7)(b) of Canada-U.S. ...

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 RRSPs and RCAs not treated as flow-through entities under Art. ...

8 September 2017 External T.I. 2014-0549771E5- Article XXIX-A:3-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 "person related thereto" defined by ITA meaning of "related person" After noting the relevance of domestic definitions of a term under Art. ...

14 December 1992 Income Tax Severed Letter 912281A F- PROFESSIONS DÉPENDANTES\AVANTAGES EN VERTU D'UN EMPLOI-- summary under Subsection 7(4) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(4) A Canadian employee who exercised an employee stock option after becoming a non-resident of Canada would be taxable in Canada on the benefit subject to the provisions of any tax convention. ...

18 April 2001 External T.I. 2001-0074995 F- Indemnité journalière de grossesse de France-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) French maternity allowances were taxable CCRA indicated that daily pregnancy benefits paid by the French government constituted income which was taxable for Canadian tax purposes, and was not exempted under the Canada-France Convention. ...

9 January 2001 External T.I. 2000-0042545- Immovable property-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The exception for real property in which the business of the enterprises carried on apparently was viewed as being available where the shares of a private corporation resident in Canada actively carried on a farming business in Canada. ...

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