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Julie Colden, Éric Lévesque, "An In-Depth Look at the Hybrid Rules in the Fifth Protocol", 2017 Annual CTF Conference-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Non-application of IV(6) to non-U.S. ...

.-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Alternative OECD-suggested approaches to Limitations-on-Benefits clauses (p.767) 1. ...

Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) Meaning of transaction (p. 972) [W]hile the official French version of the ITA translates “transaction” as “operation,” which is defined to include "une convention, un mecanisme ou un evenement," the official French version of the MLI refers to "une transaction" and "un montage"— the latter of which is also broad and clearly contemplates a series of transactions. ...

Corrado Cardarelli, Peter Keenan, "Planning Around the Anti-Hybrid Rules in the Canada-US Tax Treaty", 2013 Conference Report (Canadian Tax Foundation), pp.16:1-27-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 IV(6)(a) and (b) not satisfied where sole shareholder of ULC is LLC (p.16:6) Following the approval by the CRA of the two-step process, the expectation was that the process could be combined with the lookthrough rule in article IV(6) to overcome the anti-hybrid rule in article IV(7)(b) in the case of a fiscally transparent LLC that is the sole shareholder of a fiscally transparent ULC where the members of the LLC are qualifying US residents. ...