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2015 Ruling 2014-0542411R3- Carrying on business in Canada and PE-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 PE in Canada of ForCo avoided through seconding employees to its Cdn sister and meeting in Canada up to 90 days annually only offsite Key role of ForCo in Projects CanCo (an indirect CBCA subsidiary of a foreign public company), which had knowledge of the Canadian markets and whose Canadian customers preferred local suppliers, entered into contracts to perform two Canadian projects (the “Projects”). ...

18 April 2019 Internal T.I. 2018-0753621I7- Subsection 247(12)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. ...