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2008 Ruling 2008-0272141R3- Conversion of Delaware corporation into LLC-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 disposition of tcp through U.S. holdco was exempted The shares of a U.S. corporation (D Co) holding two Canadian subsidiaries (G Co and H Co) whose shares are taxable Canadian property are contributed by its U.S. ...

12 March 2013 External T.I. 2013-0476351E5- Taxation of Roth IRA-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 election available to defer taxation on Roth IRA income A Roth IRA is not a registered plan under the ITA, but Article XVIII will generally apply to distributions to a Canadian resident individual out of a Roth IRA if the distribution would be excluded from income tax if paid to a US resident. ...

3 February 2014 External T.I. 2012-0464541E5- Article 15 of the Canada-Germany Income Tax Treaty-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 183-day test One of the components of the safe-harbour rule in Art. 15(2)(a) of the Canada-Germany Treaty is that the employee is present in Canada for a period or periods not exceeding in the aggregate 183 days in any 12 month period commencing or ending in the fiscal year. ...

28 May 2015 IFA Roundtable Q. 2, 2015-0581551C6- IFA 2015 Q.2: GAAR and treaty shopping-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 What is CRA's position on the application of the GAAR to treaty shopping arrangements? ...

5 October 2012 Roundtable, 2012-0451251C6 F- Excess of foreign tax withheld at source-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose tax withheld in excess of Treaty-rate is not deductible as an expense Tax is systematically withheld on income from ADRs at above the maximum rates permitted by the conventions. ...

CRA also indicated that neither Article 11 nor Article 17 of the Canada-UK Convention would apply to relieve taxation. ...

Convention. ...

17 October 2012 External T.I. 2011-0428781E5- US LLC owned by Canadian residents-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 U.S. ...

28 May 2015 IFA Roundtable Q. 12, 2015-0581521C6- IFA 2015 Q.12: Canada-Switzerland Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 resolution of conflicting French and English Treaty versions of Swiss Treaty in taxpayer's favour A corporation resident in Switzerland ("Swissco") wholly-owns "Holdco," which wholly-owns "Canco"). ...

28 July 2015 External T.I. 2014-0522271E5- REIT Distribution- Article 21 Canada-Sweden Treaty-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Treaty rate on REIT distributions to Swedish resident An income distribution by a Canadian REIT to a Swedish resident was subject to a reduced rate of Part XIII witholding of 15% pursuant to Art. 21, para. 2 of the Canada-Sweden Treaty. ...