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Article Summary
Déry, David A. Ward, "Interpretation of Double Taxation Conventions", Cahiers de droit Fiscal International, Volume LXXVIIIa, p. 259. -- summary under Income Tax Conventions
Ward, "Interpretation of Double Taxation Conventions", Cahiers de droit Fiscal International, Volume LXXVIIIa, p. 259.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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Stéphane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Koichi Inoue, Jürgen Lüdicke, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Kees van Raad, Richard Vann, Bertil Wiman, "The Proposed OECD Multilateral Instrument Amending Tax Treaties", Bulletin for International Taxation, December 2016, p. 683 -- summary under Income Tax Conventions
It would be necessary to turn to the MLI for the wording of the modifying provision and to read the bilateral convention along with, and as modified by, the MLI. Thus, rather than seeking to delete and replace wording in existing bilateral conventions, within the scope of matters covered by the MLI, one would turn from the bilateral convention to the MLI for the relevant wording. ... That task is relatively easy where the bilateral convention is based upon the OECD Model or UN Model, but as far harder task where the wording departs from either of those Models. ...
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Baxter, Double Taxation Agreements and International Tax Law, Sweet Maxwell (London, 1991). -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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Michael Lang, "Income Allocation Issues Under Tax Treaties", Tax Notes International, April 21, 2014, p. 285. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions No implications of specific safe harbours (p. 287) Therefore, a special provision is no indication that something else applies outside its explicitly defined scope of application. ... Relevance of subsequent OECD Commentary (p. 289) The differentiated reasoning adopted by the court, however, is not very conclusive: "A later OECD Commentary should only be of assistance if not in conflict with the Commentary in existence at the time of the Convention." ...
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R. Ian Crosbie, "Recent Development affecting Residence under Canada's Income Tax Conventions", Corporate Finance, Vol. VII, No. 2, 1999, p. 606. -- summary under Article 4
Ian Crosbie, "Recent Development affecting Residence under Canada's Income Tax Conventions", Corporate Finance, Vol. VII, No. 2, 1999, p. 606.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ...
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Edward Miller, "Potential Limitations of the Limitation on Benefits Clause in the Fifth Protocol to the Canada-U.S. Income Tax Convention", International Tax, CCH, December 2007, No. 37, p. 4. -- summary under Article 29A
Income Tax Convention", International Tax, CCH, December 2007, No. 37, p. 4.-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A ...
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James S. Hausman, "Interpreting Tax Treaties - A Canadian Perspective", Bulletin for International Fiscal Documentation, Vol. 55, No. 3, March 2001, p. 93. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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David A. Ward, "Principles to be Applied in Interpreting Tax Treaties", 1977 Canadian Tax Journal, p. 263. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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David A. Ward, "Conflicting (Domestic and Treaty) Interpretational Approaches in the Two Countries: A Canadian Perspective", Cross-Border Taxation Issues and Development 1996, International Fiscal Association, p. 531. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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Wolfe D. Goodman, "When can the CCRA enforce a U.S. tax liability under Article XXVI-A of the Convention?", Goodman on Estate Planning, Vol. IX, no. 3, p. 716. -- summary under Article 26A
Goodman, "When can the CCRA enforce a U.S. tax liability under Article XXVI-A of the Convention?", ... IX, no. 3, p. 716.-- summary under Article 26A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26A ...