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Convention. ...

Convention, assuming the lender is a U.S. resident. ...

Income Tax Convention, the Canadian-resident shareholder of an S-Corp will not obtain a Canadian foreign tax credit for the U.S. tax paid by him in respect of the income of the S-Corp unless he had income from other sources of the United States that was subject to Canadian income tax. ...

17 July 1992 T.I. 920168 (January- February 1993 Access Letter, p. 35, ¶C180-134)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Whether an arrangement under which the U.S. seller assigned its receivables, or nominated a U.S. bank as its agent to collect the receivables, gave rise to a change in beneficial ownership of the interest on the receivables could only be determined after an examination of the relevant documentation. ...

(Tax Window, No. 6, p. 7, ¶1361)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 An individual is resident of Canada for 15 years or more (paragraph 9) if he is a resident of Canada for discrete periods aggregating 15 years and each consisting of at least 12 consecutive months. ...

28 May 2009 Internal T.I. 2009-0319161I7- Canada-US Treaty- Article XXIX A(3)-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A CRA will therefore interpret the term 'registered securities dealer' to mean: a 'registered securities dealer' for the purposes of the Income Tax Act (Canada); or a 'dealer in securities' for the purposes of Section 475 of the Internal Revenue Code and whose dealings as such are regulated under US federal or state-level securities legislation. ...

2006 Ruling 2006-0173601R3- Permanent establishment-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A representative office of a foreign bank whose activities were restricted to the general promotion in Canada of the foreign bank's products and services, and acting as a liaison between Canadian customers (or potential customers) and the foreign bank, would be considered to be engaged in activities of a preparatory or auxiliary nature and, therefore, would not be considered to be a permanent establishment under the applicable Treaty. ...

15 November 1990 TI 902937-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Interest on a borrowing by a U.S. resident to acquire a rental property in Canada would be subject to Canadian withholding tax if the rental property was a rental business, as the interest would be borne by a permanent establishment in Canada and, therefore, would arise in Canada, thereby giving Canada the right to tax the interest under s. 212(13.2) of the Act. ...

(Tax Window, No. 27, p. 17, ¶2329)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A U.K. citizen who is resident in Canada for 20 years, then resident in the U.K. for seven years, before he sells a U.K. real property in respect of which he had made an election under s. 48(1)(c) upon ceasing to be a resident in Canada, will be exempt from tax on the disposition pursuant to Article XIII(8). ...

14 October 1992 Rulings Tax Seminar Central Region 9230057-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 "We would definitely recommend that the Department challenge any arrangement where a Canadian distributor supposedly enters into an agreement with a non-resident person to acquire the right to produce or reproduce video tapes and then turns around and enters into another contract with the same non-resident, or a person related or connected to that non-resident, to have the video tapes reproduced by such a person. ...