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Carl Irvine, Todd Miller, "Canadian Branch Profits Tax - Challenging the Denial of Treaty-Benefits for US LLCs", Newsletter - TerraLex Connections, 26 December 2013 -- summary under Article 4

Carl Irvine, Todd Miller, "Canadian Branch Profits Tax- Challenging the Denial of Treaty-Benefits for US LLCs", Newsletter- TerraLex Connections, 26 December 2013-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 CRA view that Art. ...

Ian Zahra, "The Principal Purpose Test: A Critical Analysis of Its Substantive and Procedural Aspects – Part I", Bulletin for International Taxation, November 2019, p. 609 -- summary under Article 7(1)

“Notwithstanding the other provisions of this Convention”. … [After referencing view of Danon:] If a purported abusive arrangement can be dealt with by the PPT and a SAAR, the SAAR should prevail, provided that the SAAR does cover the same situation. ...

Jan de Goede, Ruxandra Vlasceanu, "Permanent Establishment Implications for Coordination Centres in the Oil and Gas Industry", Bulletin for International Taxation, September 2013, p. 466. -- summary under Article 5

.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Issue: pe status of oil and gas coordination centres (p. 466) This article analyses what seems to be a more general issue in the oil and gas industry, i.e. the PE implications arising from the establishment of an unincorporated coordination centre that provides support to various exploration and production blocks within the same jurisdiction…. ...

Abraham Leitner, Peter Glicklich, "Uncertainty Remains Under the Services PE Provision in the U.S.-Canada Income Tax Treaty", Tax Management International Journal, 2015, p. 784 -- summary under Article 5

-Canada Income Tax Treaty", Tax Management International Journal, 2015, p. 784-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 CRA not accepting apparent Joint Committee view that services PE in Canada-U.S. ...

Ian Crosbie, "Recent Transactions of Interest, Part I", 2015 CTF Annual Conference paper -- summary under Subsection 212.3(2)

The PUC created by the issuance of Whiting Bidco shares to Whiting would have been sufficient to offset one of the FA investments (as it did), but there would have been no further PUC available to offset the other FA investment, meaning that a dividend equal to the value of the transaction could have been deemed to have been paid by Whiting Bidco to Whiting, and could have been subject to withholding tax at a 5 percent rate (under the Canada-U.S. tax convention.). ...

Christian Ehlermann, Marla Castelon, "When Does a Dependent Agent Act Habitually?", Tax Notes International, 26 September 2016, p. 1141 -- summary under Article 5

", Tax Notes International, 26 September 2016, p. 1141-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Proposed change in BEPS final action plan to agency PE effectively elevates "habitually" requirement (p. 1142) [A]rticle 5(5) will no longer require the dependent agent to conclude contracts in the principal's name; it will be sufficient that the dependent agent habitually plays the principal role leading to the routine conclusion of contracts without material modification by the enterprise — that is, the principal. ...

Richard Tremblay, Ilana Ludwin, "Indian Supreme Court Diverges from OECD Guidelines, Relies on Questionable Canadian Precedent, in Deciding PE Issue in Formula One", Tax Management International Journal, 2018, p. 125 -- summary under Article 5

Richard Tremblay, Ilana Ludwin, "Indian Supreme Court Diverges from OECD Guidelines, Relies on Questionable Canadian Precedent, in Deciding PE Issue in Formula One", Tax Management International Journal, 2018, p. 125-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Finding of PE in Formula One (p. 125) The Supreme Court of India ("Supreme Court") decided in 2017 [in Formula One] that Formula One World Championship Limited ("FOWC"), a U.K. corporation, had a permanent establishment in India as a result of its role in the 2011-2013 Indian Grand Prix races…. ...

Matias Milet, Jennifer Horton, "The Canada Revenue Agency’s Interpretation of the 2017 OECD Transfer Pricing Guidelines", International Tax (Wolters Kluwer CCH), No. 103, December 2018, p.10 -- summary under Subsection 247(2)

. … As noted…in Prévost Car …later guidance from the OECD can be helpful to the interpretation and application of existing bilateral tax treaties, when it "represent[s] a fair Interpretation" of the OECD Model Tax Convention (the "Model Treaty") and does not conflict with the guidance that was in place at the time a specific treaty was entered into. ...

Marco Rossi, "An Italian Perspective on the Concept of Beneficial Ownership", Tax Notes International, December 23, 2013, p. 1133. -- summary under Article 11

.-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Application of 1977 OECD commentary on beneficial ownershp to Italian manatarios (p. 1139) The commentary stated that the limitation of tax in the state of source was unavailable when an intermediary, such as an agent or nominee, was interposed between the beneficiary and payer, unless the beneficial owner of the income is a resident of the other contracting state. ...

Abraham Leitner, "BEPS Targets Commonly Used Canada-U.S. Hybrid Structures", Tax Notes International, 9 February 2015, p. 531. -- summary under Article 11

.-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 BEPS Report (p. 531) …‘‘Neutralising the Effects of Hybrid Mismatch Arrangements,'' was released by the OECD on September 16, 2014, as part of a package of seven reports addressing different aspects of the BEPS action plan. ...

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