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Marin – Tax Court of Canada confirms that FTC domestic and Treaty provisions are applied re the particular year in which the subject income was earned

The Queen, 2022 CCI 49 under s. 126(7) – non-business income tax, Treaties – Income Tax Conventions, Art. 6, Art. 24. ...

Levett – Federal Court of Appeal finds that taxpayer stonewalling satisfied the Swiss exchange-of-information requirement that CRA had “pursued all reasonable [domestic] means available”

Canada (Attorney General), 2022 FCA 117 under Treaties –Income Tax Conventions- Art. 27. ...

CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction

Summaries of 5 October 2021 Internal T.I. 2021-0903361I7 under Treaties – Income Tax Conventions – Art. 4, Art. 29. ...

CRA discusses whether a USco can be subject to Part I tax as a result of Canadian home offices of employees

Summaries of 17 May 2023 IFA Roundtable, Q.5 under s. 115(1)(a)(ii), s. 253(a), s. 253(b) and Treaties – Income Tax Conventions – Art. ...

CRA indicates that the PPT object and purpose test is met where individuals in a Treaty country transfer their Canco shares to a Treaty-resident Holdco to reduce dividend withholding

Summary of 17 May 2023 IFA Roundtable, Q.7 under Treaties – Income Tax Conventions – Art. 10. ...

RBC – English Court of Appeal finds that an oil and gas royalty is not income from immovable property under the Canada-U.K. Treaty where the recipient never had any interest in the oil field

Summaries of Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs [2023] EWCA Civ 695 under Treaties – Income Tax Conventions – Art. 6, Art. 12. ...

We have translated 6 more CRA interpretations

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-09-13 31 July 2002 Internal T.I. 2002-0136937 F- Placement Français "Assurance-salaire-vie Treaties- Income Tax Conventions- Article 18 withdrawal from French employee-contribution plan (assurance-salaire-vie) was not a “pension” Income Tax Act- Section 233.3- Subsection 233.3(1)- Reporting Entity cost amount of foreign retirement plan may have been stepped up under s. 128.1(1) 30 September 2002 Internal T.I. 2002-0152107 F- BRANCHEMENT A DES SERVICES PUBLICS Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(c)- Subparagraph 8(1)(c)(iii) utilities do not extend to cable, satellite TV and internet in light of s. 8(1) preamble Income Tax Act- Section 62- Subsection 62(3)- Paragraph 62(3)(g) utilities include cable, satellite TV and internet 2 October 2002 Internal T.I. 2002-0153417 F- REVENU D'EMPLOI ORGANISATION Income Tax Regulations- Regulation 8900- Subsection 8900(1)- Paragraph 8900(1)(b) Montreal IFC not a prescribed organization 1 October 2002 Internal T.I. 2002-0154887 F- DEPENSES DE REPAS Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(g) simplified method not available for self-employed individuals 2002-08-30 13 September 2002 External T.I. 2002-0159525 F- Non-Arm's Length Sale of Shares Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) CCRA does not generally presume that an uncle and nephew do not deal at arm’s length 11 September 2002 External T.I. 2002-0161005 F- REÇU POUR DON- MUNICIPALITÉ Income Tax Act- 101-110- Section 110.1- Subsection 110.1(2) a local municipality incorporated under the Quebec Municipal Territorial Organization Act could issue receipts for gifts received ...

PepsiCo - Federal Court of Australia finds that part of the purchase of concentrate by an Australian bottler from an Australian PepsiCo company was a trademark royalty

Summary of PepsiCo, Inc v Commissioner of Taxation [2023] FCA 1490 under Treaties – Income Tax Conventions – Art. 12. ...

We have translated 6 more CRA interpretations

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-07-05 19 June 2002 External T.I. 2000-0020525 F- Article 19 Canada- France Tax Treaty Treaties- Income Tax Conventions- Article 19 question of whether French payer was a governmental instrumentality referred to group which could engage in competent authority matters 14 June 2002 External T.I. 2001-0103755 F- Cumulative Eligible Capital on Amalgamation Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(f) Amalco should not have 2 CEC adjustment times 28 June 2002 Internal T.I. 2002-0132427 F- RDTOH Income Tax Act- Section 129- Subsection 129(1) RDTOH reduced by dividend refund even if time limit for claiming the dividend refund has passed 18 July 2002 Internal T.I. 2002-0135177 F- TRANSPORT DE MARCHANDISES Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(g) goods include property not intended for sale, such as mail, but do not include securities 25 July 2002 Internal T.I. 2002-0139877 F- ASSURANCE INVALIDITE-PARITE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) contributions in years 2 and 3 could be deducted from subsequent parity adjustment to contribution made in year 1 10 September 1997 External T.I. 9704715 F- RÉCOMPENSE- PRIX D'EXCELLENCE EN XXXXXXXXXX Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) prize excluded because received in respect of employment ...

CRA discusses the different treatment of losses under Pt. XIV, and Art. X(6) of the Canada-US Treaty

Summary of 21 October 2021 Internal T.I. 2020-0872281I7 under Treaties – Income Tax Conventions – Art. 10. ...

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Marin – Tax Court of Canada confirms that FTC domestic and Treaty provisions are applied re the particular year in which the subject income was earned

Levett – Federal Court of Appeal finds that taxpayer stonewalling satisfied the Swiss exchange-of-information requirement that CRA had “pursued all reasonable [domestic] means available”

CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction

CRA discusses whether a USco can be subject to Part I tax as a result of Canadian home offices of employees

CRA indicates that the PPT object and purpose test is met where individuals in a Treaty country transfer their Canco shares to a Treaty-resident Holdco to reduce dividend withholding

RBC – English Court of Appeal finds that an oil and gas royalty is not income from immovable property under the Canada-U.K. Treaty where the recipient never had any interest in the oil field

We have translated 6 more CRA interpretations

PepsiCo - Federal Court of Australia finds that part of the purchase of concentrate by an Australian bottler from an Australian PepsiCo company was a trademark royalty

We have translated 6 more CRA interpretations

CRA discusses the different treatment of losses under Pt. XIV, and Art. X(6) of the Canada-US Treaty

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