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15 May 2019 IFA Roundtable Q. 2, 2019-0798751C6- Shared workspaces and PE-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 a Canadian shared-work space can readily constitute a PE In the following examples, will a U.S. resident carrying on business in Canada, be considered to be a permanent establishment (“PE”) in Canada, assuming Arts. ...

15 May 2019 IFA Roundtable Q. 8, 2019-0798841C6- Active Trade or Business Test under the LOB Clause-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Art. ...

18 April 2019 Internal T.I. 2018-0753621I7- Subsection 247(12)-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 secondary adjustment benefit to a NR sister was a dividend for Treaty purposes Parentco, a U.S. ...

3 December 2019 CTF Roundtable Q. 2, 2019-0824381C6- Foreign taxes paid-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 US and UK Treaties do not eliminate FTC requirement that the taxes be paid Art. ...

18 July 2018 Internal T.I. 2018-0766441I7- Article XXIX(5) and 91(5)-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 agreement with CASD terminated when S Corp. ceased to be fiscally transparent A Canadian resident (and US citizen) had an agreement with the Canadian Competent Authority under Art. ...

2020 Ruling 2019-0801011R3- Article 13(4) of the Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 a Treaty exempted the gain on the sale of a non-resident holding company holding Canadian vacant land Background Mr. ...

15 September 2020 IFA Roundtable Q. 4, 2020-0853391C6- IFA 2020 Q4: Impact Covid-19 on CRA procedures-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 COVID-19 has not changed Treaty time limitations Respecting the pandemic effect on various CRA international programs, CRA indicated: APA and MAP program operations have gradually resumed, and CRA is in contact with its treaty partners using virtual tools such as teleconferencing and, where possible, video-conferencing. ...

9 July 2021 Internal T.I. 2021-0893981I7- CERB received by non-residents-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 elimination of double taxation Art. addresses relief for taxation by Treaty partner of CERB payments After noting that payments (“CERB Payments”) made pursuant to the Canada Emergency Response Benefit Act (the “CERB Act”) to a non-resident individual were required by ss. 56(1)(r)(iv.1) and 115(1)(a)(iii.22) to be included in computing the taxable income earned in Canada of the non-resident, CRA indicated that the “Other Income” Article of an applicable Treaty will generally apply to the payments and that, similarly to federal employment insurance compensation, it is CRA’s view that the CERB Payments constitute income arising in Canada, so that Canada generally has the right to tax CERB Payments without restriction. ...

2021 Ruling 2021-0876671R3- Transfer between US pension plans-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 the transfer of a portion of the assets and beneficiaries from an old to a new US pension plan did not result in taxable income under the IRC S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. ...

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Barbados remittance-based taxpayer is a Treaty resident under Crown Forest test Where dividends paid by a resident corporation to a resident personal discretionary trust are deemed pursuant to s. 104(19) to be received by a beneficiary that is resident, but not domiciled, in Barbados (“NR-Beneficiary”), would those dividends be subject to a reduced rate of withholding at 15% pursuant to Arts. ...