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13 June 2017 STEP Roundtable Q. 9, 2017-0697901C6- S-corporation agreements-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Cdn competent authority agreement with S-Corp. extends to income of a qualified subchapter S Corp. subsidiary thereof Where a U.S. ...

GILTI Tax-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 Cdn competent authority will not recognize claims that GILTI tax is contrary to Art. ...

19 February 1997 External T.I. 9616305- ROYALTY PAYMENTS FOR SHOWING VIDEOS IN PUBLIC-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 In noting that royalties paid for a licence to make videos available to the patrons of a health club, who view videos on installed televisions sets while they exercise, will not be exempt from withholding tax, RC stated: "Royalties in respect of the production or reproduction of motion pictures or video tapes which are not for private (home) use, including but not limited to those used in connection with television broadcasting, are not exempt. ...

12 March 1998 External T.I. 9805215- Barbados trust deemed resident of Canada-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Before concluding that Canada had the right to tax a trust that was resident in Barbados and which was deemed to be resident in Canada under s. 94(1)(c), Revenue Canada stated: "... ...

27 July 1994 External T.I. 9409325- PERMANENT ESTABLISHMENT-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "In a situation where a corporation has wholly-owned subsidiaries in Canada and the United States... with 'specialized employees' employed by the Canadian subsidiary which are required to visit work sites in the U.S. to review projects, gather data, and carry out certain tests and then return to their office in Canada to interpret lab reports, design solutions to problems, conduct discussions with regulatory and environmental agencies of the U.S. and finally prepare engineering reports, we believe that such employees may be carrying on the business of the U.S. subsidiary in Canada at a fixed place of business, that being the offices of the Canadian subsidiary and therefore the U.S. subsidiary may have a permanent establishment in Canada. ...

17 January 1996 External T.I. 9520065- BORROWINGS EFFECTIVELY CONNECTED TO A PE-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Before indicating that borrowings by a U.S. ...

3 October 2003 External T.I. 2003-0030585 F- PENSIONS ETRANGERES-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 degree of exemption for social security pension payments from Germany, Belgium or France CCRA discussed the degree of exemption of social security pension payments by a Canadian resident (who otherwise would be taxable thereon under s. 56(1)(a)(i)) from the following jurisdictions: Germany The German Bundesversicherungsanstalt plan is a social security plan for the purposes of the treaty. ...

29 September 2003 External T.I. 2003-0013435 F- Pension Belge-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Belgian National Pensions Office was a Belgian government instrumentality for purposes of the former Art. 18(2) exemption Regarding whether a resident employee's retirement pension received from the Belgian National Pensions Office was exempted under Art. 18 of the 2002 version of the Canada-Belgium treaty, CCRA indicated that, based on its understanding that the National Pensions Office would be a Belgian government instrumentality, the pension (which otherwise would have been taxable) was exempted under Art. 18(2), so that, although the resident employee would be required to include the pension in income under s. 56(1)(a)(i), but would be entitled to a corresponding deduction in computing taxable income under s. 110(1)(f)(i). ...

Particular attention should also be paid to Article XVIII(5) of the 1980 Canada-United States Income Tax Convention in respect of such payments. ...

After noting that under the Cananda-France convention, the individual appeared to be entitled to apply to the French government for a refund of the avoir fiscal, CCRA indicated that the full $10,000 gross amount was required to be included in the individual’s income. ...