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23 July 1991 Memorandum (Tax Window, No. 7, p. 15, ¶1368)-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 By virtue of paragraph 1 of Article XIII of the Canada-Barbados Convention, the maximum withholding tax which Barbados may impose on management fees derived from Barbados is 5%. ...

.- Q.55-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 the phrase "borne by an employer in Article XV(2)(b) of the 1980 U.S. Convention means borne by the employer of the particular individual. Where a visiting U.S. employee of the U.S. parent receives direction and control from the management of the Canadian subsidiary, then that subsidiary is his employer. ...

.- Q.38-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 where the IRS alleges that a U.S. subsidiary overpaid its Canadian parent for goods, it is not necessary to refund the alleged overpayment in order to initiate competent authority negotiations (Article XXVI of U.S. Convention). ...

93 C.M.TC- Q. 15-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The reductions in rates of withholding tax pursuant to the 1991 protocol to the Mexico Convention (arising when Mexico agrees to a lower rate in other treaties) do not take effect until the time that the lower rates of withholding tax take effect under the relevant tax treaty between Mexico and the third country, and only apply to the extent that the particular types of payment receive a lower rate of withholding tax under the other tax treaty. ...

No. 1, ¶1013)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Where an individual who has Canadian source income which is fully taxable in Canada (e.g., employment income) but who is deemed by the tie-break rules in the Canada-Japan Income Tax Convention to be a resident of Japan, such interest income will be included in his income in the usual way, the resulting tax will be reduced to ensure that the effective rate of tax and the gross amount of the interest is limited to 10%. ...

After referencing its comments at 2019-0824551C6 on the TAP Committee responsibility for the PPT and noting that it was premature for any assessments to have been issued (the first deadline for NR4 filings for payments to which the PPT might apply was March 31, 2021; and the returns for the earliest 12-month taxation years to which the MLI could apply had a filing due date of November 30, 2021), CRA noted that it had received one pre-ruling consultation request: The underlying fact pattern of the request involved the payment of a dividend by a Canadian corporation (“Canco”) to a corporation residing in another jurisdiction (“NRCo”) with which Canada has a tax treaty (“Convention”). ... Canco requested confirmation that the Convention would apply to reduce the Canadian withholding tax rate of 25%, as provided in subsection 212(2), to a 5% withholding tax rate under the Convention, notwithstanding the MLI. … [T]he CRA will continue to contemplate the application of the GAAR to transactions undertaken primarily to secure a tax benefit afforded by a tax treaty. ...

Pending updates to IC76-12, Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention related to forms NR301, NR302, and NR303 IC76-12R6 "Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention" ...

2 December 2014 CTF Roundtable, Q. 7-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A U.S. business was "substantial" for para. 3 purposes with 50% of revenues and assets and 10% of employees In what circumstances would CRA consider a US business to be "substantial" in relation to a Canadian business for purposes of Art. XXIX-A, para. 3 of the Canada–US tax Convention (the LOB Article)? CRA responded: For the purpose of determining whether the US business was "substantial" in relation to the Canadian operations in the context of [various] rulings, a number of factors were considered which included, but were not limited to: the relative amount of assets and revenues, number of employees involved in each jurisdiction, and in certain circumstances the relative amount of income and compensation expenses. … [S]ome of the more significant comparative ratios are summarized below: ...

Also included are payments made to employees or members of the association to assist them in covering their expenses to attend various conventions and meetings as delegates on behalf of the association, provided attendance at such conventions and meetings is to further the aims and objectives of the association. … ...

Factor-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A ...