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Kevyn Nightingale, David Turchen, "The US Tax Implications of a Tax-Free Savings Account", CCH Tax Topics, No. 2146, April 25, 2013, p.1, at 2-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Most of the larger accounting firms are taking the conservative position that a TFSA is not treaty-protected.... ... Convention in its application to a U.S. citizen or resident who has a TFSA, they state (at pp. 2-3): The sole remaining question is whether a TFSA is operated "exclusively to provide pension … benefits". ...

Kasper Dziurdź, "Article 15 of the OECD Model: The 183 Day Rule and the Meaning of 'Borne by a Permanent Establishment'", OECD, Bulletin for International Taxation, March 2013, p. 122-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 After reviewing the history of Article 15(2) of the OECD Model Convention, commencing with the Germany-Sweden Income Tax and Capital Treaty (1928), they stated (at p. 124): The object and purpose of the 183-day rule is, therefore, to facilitate the international movement of personnel and the operations of enterprises engaged in international trade. ...

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Re-sourcing of capital gains and derivative gains (p.7) A common scenario in which a treaty re-sourcing rule may apply is where a Canadian resident realizes a capital gain from a disposition of foreign-company shares that is taxable in the company's state of residence under a treaty…. ... Income Tax Convention (the "U.S. Treaty") may also be relevant in the context of payments by Canadian residents under derivative instruments (which would generally be sourced to Canada under Canadian principles) where such payments are subject to U.S. withholding under the recently enacted "dividend equivalent payment" rules in section 871(m) of the Internal Revenue Code (the "Code"). ...

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Calderwood, "The Competent Authority Function: A Perspective from Revenue Canada", 1989 Conference Report, c. 39-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 ...

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Elio Andrea Palmitessa, "Italian Supreme Court Applies the Beneficial Ownership Clause to Pure Holding Companies", Tax Notes International, April 17, 2017, p. 259-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Dividend withholding avoidance (p. 259) [A] U.S. corporation owned a holding company in France, which in turn owned an Italian subsidiary. ... Focus instead on autonomy of decision-making (p. 261) Ultimately, the Supreme Court held that beneficial ownership — which can be a key issue in the context of the domestic antiavoidance rules as well as the antiabuse principle of article 31 of the Vienna Convention on the Law of Treaties — should be tested, considering the nature and the functions of the direct recipient of income concerning its ability to make autonomous decisions regarding and exercise power over the funds. ...

", Tax Notes International, 10 February 2020, p. 655-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Treaty-limits on what Canada may tax on sales by U.S. into Canada (p.658) Under the prior version of Code s. 863, the gross revenue of a U.S. person from goods produced by it in the U.S. and sold outside the U.S. could often be allocated partly to the other country for U.S. foreign tax credit (FTC) purposes. ... CRA “Canada – US Tax Convention – Agreement between Competent Authorities on the Interpretation of Article V11 (Business Profits)”, (June 26, 2012). ...