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CRA states that it lacks jurisdiction to determine whether a trust can elect under Art. XIII(7) of the Canada-U.S. Treaty to avoid double taxation of a s. 104(4)(b) gain

Summaries of 3 February 2022 Internal T.I. 2021-0922301I7 under Treaties – income Tax Conventions – Art. 13, Art. 24. ...

CRA finds that remotely servicing a Canadian customer did not give rise to a services PE in Canada

Summaries of 29 November 2022 CTF Roundtable, Q.4 under Reg. 105(1) and Treaties – Income Tax Conventions – Art. 5. ...

CRA finds that employment income does not arise in the U.S. for Treaty purposes to the extent the duties are performed in a Canadian home office

Summaries of 11 April 2023 Internal T.I. 2023-0964101I7 under Treaties – Income Tax Conventions – Art. 24, Art. 8. ...

CRA indicates that Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion

Summary of 17 May 2023 IFA Roundtable, Q.4 under Treaties – Income Tax Conventions – Art. 29. ...

CRA treats a Swiss collective investment vehicle as a flow-through for purposes of the pension/ retirement fund dividend exemption in the Canada-Swiss treaty

Summary of 2024 Ruling 2019-0817961R3 under Treaties – Income Tax Conventions – Art. 10. ...

CRA indicates that it has no discretion to extend the 2-year refund application deadline under s. 227(6)

. … [T]here is no relief available to a taxpayer under the Canada-Barbados Tax Convention to override the two-year limitation period required by subsection 227(6). ...

CRA finds that capital for purposes of determining a Canadian Treaty-reduced dividend withholding rate of 5% references stated capital

Summary of 14 December 2023 External T.I. 2019-0820291E5 under Treaties – Income Tax Conventions – Art. 10. ...

CRA indicates that the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time

Summary of 23 November 2023 Internal T.I. 2020-0850381I7 under Treaties – Income Tax Conventions – Art. 5. ...

CRA suggests that a non-resident’s increasing its voting shareholding in Canco to access the Treaty-reduced dividend withholding rate does not engage the PPT

Summary of 15 May 2024 IFA Roundtable, Q.1 under Treaties – Income Tax Conventions – Art. 10. ...

CRA explains the credit for US estate taxes under Art XXIX-B(6)(a) of the Canada-US treaty

Summary of 4 June 2024 STEP Roundtable, Q.11 under Treaties – Income Tax Conventions – Art. 29B. ...

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