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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. ...

XIX, para. 1 of the Convention with France. CRA indicated that, with her net income being lower than his, he could not claim child care expenses as “only the spouse or common-law partner with the lowest net worldwide income (including nil income) can generally deduct these expenses.” ...

15 August 1997 External T.I. 9711265- RESIDENCE OF SICAVS-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Sociétés d'investissement à capital variable are not considered by RC to be residents of a contracting state as they are not liable to taxation in their own right. ...

22 March 1994 Internal T.I. 9402046- CENTRE OF VITAL INTERESTS- XXXXXXXXXX EMPLOYEE (4093- U5-100-4)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Where a taxpayer has not severed his residential ties with Canada, RC must analyze the personal and economic ties over a period of time in order to make a determination of those more meaningful or significant ties. ...

18 March 1996 External T.I. 9600675- treaty residence- barbados insurance companies-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 A foreign affiliate incorporated in Barbados and licensed under the Exempt Insurance Act, 1983 will not be considered to be "liable to taxation" in Barbados given that its main and, most likely, source of income will effectively be exempt from taxation in Barbados for a guaranteed period of 30 years with the exception of amounts, which although expressed as an income tax, in substance represent an annual licence fee of Bds. $5,000. ...

Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Although in most cases comparing gross asset values will be the simpler (and perhaps quite often the most reasonable) method for making the 50 percent determination respecting whether a share derives its value principally from Canadian real property, depending on the facts and circumstances of a particular situation other valuation methods such as the net asset value method may be appropriate. ...

17 June 2004 IFA Roundtable Q. 2, 2004-0072381C6- Flow-through treaty benefits partnership-- summary under Article 1 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 1 CRA is revisiting the issue whether a partner resident in a treaty country should receive the benefits of a tax treaty between Canada and that treaty country where the partner is a member of a partnership formed in Canada which is transparent for Canadian tax purposes but is considered to be a foreign corporation for purposes of the treaty country's tax system, so that the partners are not actually taxable on the partnership income in the treaty country. ...

20 March 2002 Internal T.I. 2002-0126537- Article XV(2); Employee Stock Options-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 A U.S. resident employee of a Canadian corporation was paid salary of $7,000 by it and granted stock options in respect of which he ultimately realized a benefit of $543,500. ...

2000 Ruling 2000-0015753- Article 13- Canada-Netherlands Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Canadian business of oil and gas company was carried on in its properties re Netherlands Treaty exclusion from immovable property A disposition by a Netherlands resident of shares of a Canadian corporation (perhaps a Canadian holding company holding a Canadian oil and gas operating subsidiary) qualified for exemption under the Netherlands Treaty having regard to the exclusion from immovable property for property (other than rental property) in which the business of the company was carried on given that the operating company was using its oil and gas properties in its Canadian business. ...

Convention would exempt from Canadian tax the profits of a U.S. resident's Canadian branch operations derived from point-to-point cross-border motor vehicle delivery of passengers or properties but intra-Canada profits would be subject to tax under s. 115(1)(a)(ii) of the Act. ...