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S5-F1-C1- Determining an Individual’s Residence Status-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 1.41 [T]o be considered liable to tax for the purposes of the Residence article of Canada's tax treaties, an individual must be subject to the most comprehensive form of taxation as exists in the relevant country. ... The OECD Model Tax Convention states in part, as follows: "…the permanence of the home is essential; this means that the individual has arranged to have the dwelling available to him at all times continuously, and not occasionally for the purpose of a stay which, owing to the reasons for it, is necessarily of short duration (travel for pleasure, business travel, educational travel, attending a course at a school, etc). ... [T]he commentary to paragraph 2 of the Residence article of the OECD Model Tax Convention, which states in part, as follows: "If the individual has a permanent home in both Contracting States, it is necessary to look at the facts in order to ascertain with which of the two States his personal and economic relations are closer. ...

Convention), the foreign tax must be levied on net income (but not necessarily as would be computed under the Act) unless it is similar to Part XIII tax (para. 1.7). ...

Convention), the foreign tax must be levied on net income (but not necessarily as would be computed under the Act) unless it is similar to Part XIII tax (para. 1.7). ...

S5-F3-C1- Taxation of a Roth IRA-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Basic U.S. ...