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Income Tax Convention, invest in Canada through a vehicle resident in a third country. ...

That determination would also take into account surrounding circumstances and context, such as the applicable domestic tax legislation, or secondary authoritative sources such as the OECD Model Convention or the Commentary, and the intention of the signing states. ...

Tax Convention (“the Treaty”)? Summary of Preliminary Response CRA noted that, in the case of a services businesses, Folio S5-F2-C1 places weight on the place where the services are actually performed in determining where the business is carried on, and that specific CRA positions indicate that the crypto-miner receiving cryptocurrency for validating a blockchain is viewed as providing a service. ...

Official response 27 November 2018 CTF Roundtable Q. 2, 2018-0780071C6- Impact of 55(2) deeming rules Q.3- Impact of the MLI Canada introduced legislation to implement the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (the “MLI”). ...

Currently, Canada’s Income Tax Conventions with United States, Norway, Germany, United Kingdom, and New Zealand (not yet in force), contain collection assistance articles that do not limit the collection assistance of Income Tax or Excise Tax (GST) or any tax debts collected by, or on behalf of, the Government of Canada (CRA). ...

Question 2 With respect to the supply of the Building at the end of the Emphyteusis, it appears from Technical Interpretation 1195b-01 (December 1999) that GST must be computed on the difference between the value of the Land (at the end of the Emphyteusis) and the total of the Rent paid during the Emphyteusis: “La taxe est payable sur la fourniture du bâtiment au premier en date du jour du transfert de la propriété du bâtiment et du jour du transfert de la possession du bâtiment à la municipalité aux termes de la convention portant sur la fourniture, c. ...