Search - convention

12 December 2023 External T.I. 2021-0881541E5- Pension benefit from Chile-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 an exceptional COVID-related withdrawal from a Chilean pension plan qualified as an exempted pension under the Canada-Chile Treaty The Chilean government, in response to the pandemic, adopted an exceptional measure (the “Measure”) in 2020, permitting the withdrawal of up to 10% of the pension savings in the individual pension accounts managed by the Pensions Funds Administrators (“AFP”) in Chile. ...

6 December 2023 External T.I. 2017-0735631E5- Distribution of funds from an IRA and 401(k)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 a Canadian resident may access the Art. ...

After indicating that the PPT had supplanted Art. 10(8), CRA noted: Example E in para. 182 of the 2017 OECD Commentary on Art. 29 of the Model Convention describes the similar situation of a shareholder who is slightly below the threshold for access to the lower dividend rate, and who acquires shares for the purpose of taking advantage of the reduced rate. ...

15 May 2024 IFA Roundtable Q. 1, 2024-1007651C6- Principal purpose test and the UK-Canada Tax Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 marginally increasing a shareholding to access the Treaty-reduced rate likely would not engage the PPT A UK-resident corporation increased its voting shareholding of Canco the day before a dividend was paid so as to hold 10% of the shares. ...

The Directorate indicated that the presentations and exhibitions at the convention were primarily intended to enable participants to acquire new skills, learn about new developments or simply meet people or make themselves known so that, consequently, the expenditures were capital expenditures as they provided a lasting benefit to the manager. ...

Tax Treaty-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A gain of US resident from disposition of Cdn subsidiary’s shares can be considered to be from a connected business Regarding whether Canadian-source income has been derived by a U.S. resident in connection with an active trade or business in the U.S., CRA stated: 1)... ...

In the event that the multilateral convention on implementing Pillar One, Amount A is adopted, then the national DST will be removed, and CRA will be prepared to adjust its filing and compliance requirements accordingly. ...

The XXXXXXXXXX Order was issued pursuant to paragraph 5(1)(g) of the FMIOA and provides that XXXXXXXXXX officials have in Canada the privileges and immunities set out in Article V of the UN Convention. ...

2013 Ruling 2012-0444431R3- Taxable Canadian Property-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 NR partnership holding real property interests through debt A partnership (Foreign Partnership), whose non-resident members (Investors) are resident in Foreign Countries 1 through 5, uses a portion of its cash from unit and loan subscriptions to subscribe for equity of a Newco resident in Foreign Country 6 (Foreign Parent), and applies the balance of its subscription cash to subscribe for a mixture of profit-participating loans and non-interest-bearing loans of Foreign Parent (the Foreign Parent Loans). ...

12 February 2014 External T.I. 2013-0486931E5- Distribution by ULC to a Trust to a NR beneficiary-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 hybrid trust holding ULC Trust is resident in Canada, is not subject to s.75(2), has one individual beneficiary (the "Non-resident Beneficiary") who is a a qualifying person for the purposes of the Canada-U.S.Treaty, and is the sole-shareholder of a Canadian-resident unlimited liability company. ...