Search - convention

20 November 2014 Internal T.I. 2014-0539631I7- Restrictive Covenants-Part XIII (Luxembourg)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 restrictive covenant payment not eligible for relief under Lux Treaty Shares of SubCo held by LuxCo (as a capital investment) and CanCo were sold to a third party. ...

Income Tax Convention was described as an identifiable location with a certain degree of permanence in which the business of the enterprise is being carried on. ...

10 February 2015 External T.I. 2013-0484501E5- Treaties Article XV-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 $10,000 safe harbour for Canadian employment income of U.S. resident applied on calendar year basis even where he was a part-year resident Part-way through a year an individual ceased to be Canadian-resident and became a U.S. resident but derived employment income from the exercise of his employment in Canada with the same employer throughout that year, of which the portion earned while he was non-resident did not exceed Cdn.$10,000. ...

.-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 REIT income distributions to IRA at 15% An IRA account of Mr. ...

2014 Ruling 2014-0521831R3- Withholding on interest payments-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 interest paid within consolidated U.S. group re acquisition of Cdn hybrid LP is Treaty-exempt Structure US Parent Co, which is a U.S. public corporation and a qualifying person under the Canada- U.S. ...

Convention) will incorporate Canco under Part 2 of the Canada Not-for-profit Corporations Act and become the sole member and grant a non-transferable, non-exclusive licence to Canco to market and sublicense Forco's Custom Software to sub-licensees under an Agreement to sell the Custom Software in Canada. ...

23 October 2012 External T.I. 2012-0440101E5- Article X(6) Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 A US LLC, which has two US-resident members (either two corporations or an individual and a corporation) who qualify for Treaty benefits, carries on business in Canada through a permanent establishment. ...

5 August 2009 IFA Roundtable Q. 4, 2009-0319441C6- Article V(9)(b) of the Canada-US Treaty-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 services PE for services rendered between related parties Is there a discrepancy between the CRA's position that subpara. 9(b) of Article V of the Canada-U.S. ...

17 November 2015 Roundtable, 2015-0614251C6- 2015 TEI Meeting Q7 Donations to qualifying US charity-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Canadian domestic sourcing rules apply in determining whether a Canadian corporate donor to a U.S. charity has U.S. ...

2015 Ruling 2014-0550611R3- Permanent Establishment-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 home of a Canadian employee doing marketing (but no contracting) for a U.S. employer is not a PE of the U.S. employer ForCo’s Canadian business ForCo is a wholly-owned U.S. subsidiary of Foreign Parent, which is a U.S. non-profit organization. ...