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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. ...

27 July 2016 External T.I. 2015-0603271E5- Subsection 216.1(1) and permanent establishment-- summary under Article 16 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 16 Art. 16 of US Treaty permits gross withholding taxation even if PE A U.S. ...

3 February 2016 External T.I. 2014-0548111E5- U.S. tax paid in respect of an LLC's income-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Treaty sourcing rule does not trench on domestic FTC Mr. ...

15 May 2017 External T.I. 2016-0645891E5 F- Services rendered to a State-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 public-sector nurse did not provide services “to Switzerland” for purposes of Art. 18(2)(a) of the Canada-Swiss Treaty Art. 18(2)(a) of the Canada-Swiss Treaty provides that “pensions paid by, or out of funds created by, Switzerland or a political subdivision or a local authority thereof to any individual in respect of services rendered to Switzerland or subdivision or local authority thereof in the discharge of functions of a governmental nature shall be taxable only in Switzerland.” ...

You may find useful information for calculating the portion of the income and expenses of the business carried on in Canada in the Commentary on Article 7 of the 2008 OECD Model Tax Convention. ...

You may find useful information for calculating the portion of the income and expenses of the business carried on in Canada in the Commentary on Article 7 of the 2008 OECD Model Tax Convention. ...

13 June 2017 STEP Roundtable Q. 3, 2017-0693451C6- Dual-resident estate and Article (IV)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 double tax, not dual trust residence, generally will be addressed The estate of a deceased U.S. citizen may be considered a U.S. estate under U.S. domestic law, and also a Canadian resident estate under the ITA central management and control test or s. 94. ...

21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6- ULC-LLC structures & Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Treaty anti-hybrid rule (Art. 7(b)) rule applies to dividends paid by a ULC to two LLCs held by U.S. ...

24 February 2003 Internal T.I. 2002-0165537 F- Le détachement d'employés et l'article XV-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 exemption in Art. 15 of US Treaty unavailable where Canadian employee seconded to US affiliate, which reimburses for his payroll A Canadian resident was seconded to a U.S. corporation related to his Canadian employer in 2001 for a period of less than 183 days, with the U.S. corporation assuming full responsibility for the Canadian resident's employment regarding the employee’s duties in the U.S. ...

If this occurs, since at least one of the partners of LP is a Canadian resident and the interest is paid to a U.S. person, Part XIII tax is exigible, unless such payment is exempt from Canadian taxation under a provision of the Act (such as subparagraph 212(1)(b)(vii)) or the Convention. ...