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Q.4 “Special tax benefit” exclusion under Barbados Treaty Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (the “Treaty”) provides: 3. ... Income Tax Convention (the “Treaty”) USco is entitled to benefits under the Treaty (i.e., USco is a “qualifying person” for purposes of Article XXIX-A of the Treaty) 50 of the 1,000 USco employees are Canadian residents The employees are allowed, but not required, to work from home for two or three days a week Could CRA please comment on the following: Whether USco may be considered to be i. carrying on business in Canada for purposes of the Act, and, if so ii. earning income through a permanent establishment (as defined for purposes of the Treaty) in Canada Preliminary Response Despite the increase in remote working, the general principles remain unchanged. ... Income Tax Convention (the “Treaty”) REIT owns US LLC 1, a disregarded entity for U.S. income tax purposes US LLC 1 owns US LLC 2, which is also a disregarded entity for U.S. income tax purposes and a section 216 taxpayer for Canadian income tax purposes Neither US LLC 1 nor US LLC 2 is a resident of Canada for the purposes of the Treaty US LLC 1 makes an interest-bearing loan to US LLC 2. ...

If you know the person’s name but not their email address, the usual convention is “<firstname>. ... As a last resort, dare I say it, my email address also respects the first-name-dot-last-name convention, and I know my way around the Agency now so I can probably get your inquiry to right home. ...

Q.1 – PPT and Treaty threshold for 5% withholding In CRA Document 2019-0792651I7 (June 16, 2020), the CRA concluded that paragraph (8) of Article 10 (“Article 10(8)”) of the UK-Canada Income Tax Convention (the “UK-Canada Treaty”) should deny a UK resident corporation the benefit of any reduction in the 25% withholding rate applicable to a dividend paid by a Canadian corporation, where the UK corporation owned less than 10% of the voting shares of the Canadian corporation, but acquired additional shares the day before the dividend was paid such that the UK corporation held 10% at the time the dividend was paid. ... Let us consider the examples for Article 29, which is the forum in which the principal purpose test (PPT) was introduced back in the 2017 version of the OECD Model Convention. ...

Official Response 15 September 2020 IFA Roundtable Q. 2, 2020-0852741C6- IFA 2020- Q2- WHT on mismatched swap payments Q.3- MAP procedure for s. 247(2)(b) We understand that Information Circular IC71- 17R5 Guidance on Competent Authority Assistance Under Canada’s Tax Conventions is currently being revised. ...

We are also working on TPM-3, dealing with downward adjustments, in conjunction with updates to IC 71-17, Guidance on Competent Authority under Canada’s Tax Conventions. ...

Eroff: In the event that the multilateral convention on implementing Pillar One, Amount A is adopted, then the national DSTs will have to be removed, and the CRA, as the administrator of the national Canadian DST, will be prepared to adjust the filing and compliance requirements should the government decide to transition from DST to Pillar One, Amount A. ...

The same progression of tie-breaker tests is found in most of Canada’s treaties, as they mirror the OECD Model Convention. ... Additional information on the habitual abode test can be found in paras. 19 and 20 of the Official Commentary to Article IV of the OECD Model Convention. ...

Convention and Trade Shows Questions We are concerned about some positions taken by the Canada Border Services Agency in this Notice and their possible implications on the claiming of ITC by Canadian importers. 1. ... With respect to (e) Convention and Trade Shows – Are the statements in Customs Notice CN-036 consistent with the Canada Revenue Agency’s position and practices relating to the application of GST/HST in connection with conventions and trade shows? ...

Official Response 28 May 2015 IFA Roundtable, Q. 11, 2015-0581571C6 Question 12 – Conflicting versions of Swiss Treaty Article 10(2)(a) of the Canada-Switzerland Tax Convention (the “Swiss Treaty”) restricts Canada's right to tax dividends paid by Canadian-resident companies to Swiss-resident companies to a maximum of 5 per cent of the gross amount of the dividends if, inter alia, the dividends are paid to a company that “owns at least 10 per cent of the voting stock and of the capital of the company paying the dividends”. ...

Email this Content 25 September 2017 CTF Finance Roundtable on 18 July 2017 Proposals Passive Income Q.1 – Effect on lower-bracket taxpayers Oral Response Q.2 – Calculating deferral on investment income Oral Response Q.3 – Principles affecting the proposals Oral Response Q.4- Grandfathering Oral Response Income-Sprinkling Q.5 – Complexity of TOSI Oral Response Q.6 – Difference in treatment of family transactions Oral Response Q.7 – Comparison of friends in business vs. family members Oral Response Surplus-Stripping Q.8 – Pipeline transactions Oral Response Q.9 – Effects on intergenerational transfers of family businesses Oral Response Q.10 – Scope of s. 246.1 Oral Response Q.11 – Non-ancillary s. 246.1 application to NAL transactions Oral Response General Q.12 – Implementation Oral Response Additional comment on tax advantage computation This summarizes the oral responses provided by two senior Finance officials at the Finance Roundtable held at the Infinity Convention Centre in Ottawa on 25 September 2017. ...