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Jarczyk, "Info Services Firm Comments on OECD Draft Transfer Pricing Guidelines", Tax Notes International, 24 September 2012, p. 1221-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 Adresses the following "myths" respecting the application of the CUP and CUT methods to intangibles: the CUP method cannot be applied because perfect comparables do not exist; global market information is not available; and redacted licence agreements have no value. ...

-Canada Treaty's Publicly-Traded Test Should Be Resolved in Favor of Canadian Dual-Class Public Companies", Tax Management International Journal, 2011, p. 589-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A There are no valid policy reasons to prevent a dual-class public company from aggregating its share classes to satisfy; the publicly-traded test in Art. ...

Convention may relieve the director of any ultimate Canadian tax liability, RC normally insists that deductions at source be withheld by the employer and that the employee apply for a refund upon filing a return. ...

Joint Committee, "Guidance on International Income Tax Issues raised by the COVID-19", 11 June 2020 Joint Committee Submission-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 I mpact of COVID travel restrictions on day count tests for PE status The Guidance on international income tax issues raised by the COVID-19 crisis, which speaks to relief for the impact of COVID travel restrictions regarding whether a non-resident entity will have a permanent establishment under the 183-day test in the services permanent establishment provision, could also provide relief under similar provisions such as the 12-month period referenced in the building site and installation or drilling rig provisions. ...

", Tax Notes International, 10 February 2020, p. 655-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Allocation of income on sale of U.S. ... Thus as is generally the case under US income tax conventions, provision such as code sections 901(c), 904... apply for purposes of computing allowable credit under paragraph 1. ...

Jack Bernstein, "Canada-US Tax Traps for LLCs", Canadian Tax Highlights, Volume 22, Number 2, February 2014, p. 11-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 High US branch tax if use LLC (p.11) Assume that a Canco expands into the United States and forms an LLC to be the US opco. ...

Jack Bernstein, "Canada-US Tax Traps for LLCs", Canadian Tax Highlights, Volume 22, Number 2, February 2014, p. 11-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Relief under U.S. ...

Kandev, Matthew Peters, "Treaty Interpretation: The Concept of 'Beneficial Owner' in the Canadian Tax Treaty Theory and Practice", Canadian Tax Foundation, 2011 Conference Report, 26:1-60-- summary under Treaties Summary Under Tax Topics- Statutory Interpretation- Treaties In the course of reviewing the meaning of "beneficial owner" under the OECD model convention, Kandev and Peters stated (at p. 28): The jurisprudential trend in Canada, at least in theory, has been to allow increasing reliance on later commentaries, However, the practical effect of such commentaries remains uncertain. ...

The Queen, 2014 DTC 1046 [at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275 at para. 61]-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Where a treaty does not include an other income article in any form, unfortunate effects can also occur for taxpayers who, under internal law, are residents of both contracting states for tax purposes. ...

Kevyn Nightingale, Amir Pourzakikhani, "A Federal Permanent Establishment, But Not a Provincial One", Tax Topics, Wolters Kluwer, November 3, 2016, No. 2330, p. 1-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 CRA recently agreed with the position of a U.S. ...