Search - convention

20 December 1994 External T.I. 9421435- ROYALTIES AND CANADA-UK INCOME TAX CONVENTION-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 With respect to a situation where a Canadian company pays royalties to a resident of the U.K. for the right to reproduce certain movies, television series and children's programs in video format with the resulting videos being sold to distributors who would, in turn, rent or sell the videos to the public for private use, RC stated "that if the payments are computed on the basis of the number of times a video movie is shown and/or viewed rather than on the number of copies of the video produced, the payments would not fall within the exemption in paragraph 3 of Article 12 as they would not be considered to be in respect of the production or reproduction of the work". ...

5 February 2001 External T.I. 2000-0032695 F- Convention fiscale Canada-France-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 profits based consulting fee paid to French company with no PE in Canada was exempted under Art. 7 of the Canada-France treaty A CCPC (“Canco”) agreed to pay a French company (“Franceco”) for its consulting services, aimed at identifying and connecting with potential clients in France, a fixed basic fee, as well as an additional variable fee based on the results obtained. ...

10 January 2014 Internal T.I. 2013-0505911I7- Meaning of "assembly project" in Brazil Convention-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "assembly" and "installation" project Art. ...

2012 Ruling 2012-0435211R3- Article XXIX-A(3) of the Canada-US Tax Convention-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A US Holdco in Chap. 11 receives dividend Holdco, which had been a listed U.S. company, was taken private by L5, which is a fund whose members are not known. ...

Convention-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 test of a real property security under the Canada-U.S. ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit”-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion Art. ...

29 March 2006 Internal T.I. 2006-0171171I7 F- Convention de retraite-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement plan was not an RCA because benefits were unreasonable A plan set up to provide benefits to officers of a corporation was not a retirement compensation arrangement (RCA) since the benefits to be paid were not reasonable in the circumstances. ...

2 May 2001 Internal T.I. 2001-007939 F- CONVENTION D'EMISSION D'ACTIONS-- summary under Subsection 7(2) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(2) whether s. 7(2) applied turned on whether shares were held as trustee After providing an overview of s. 7(2), the Directorate noted that in this case whether it applied turned on a factual determination of whether shares were held by a person as trustee. ...

28 November 2003 External T.I. 2003-0046025 F- CONVENTION DE RETRAITE DEDUCTIONS-- summary under Paragraph 20(1)(r) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(r) s. 20(1)(r) deduction is limited by s. 67 CRA indicated that the deduction under s. 20(1)(r) could be limited by s. 67 and that there was nothing in s. 152(3.1) that would restrict its application to the s. 20(1)(r) deduction. ...

20 August 2008 External T.I. 2008-0288561E5 F- Convention de partage d'une société de personnes-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) CRA generally does not challenge sharing agreements based on each partner’s contribution After indicating that an agreement to allocate income to a retired partner generally would be respected but for there being no partnership net income, CRA went on to state: Generally …CRA … does not question the validity of a partnership sharing agreement that is based on the contribution of each partner. ...