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Administrative Policy summary
12 July 1991 Memorandum (Tax Window, No. 6, p. 3, ¶1352) -- summary under Article 27A
12 July 1991 Memorandum (Tax Window, No. 6, p. 3, ¶1352)-- summary under Article 27A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27A General discussion. ...
Administrative Policy summary
Income Tax Technical News, No. 35, 26 February 2007, "Treaty Residence - Residence of Convenience" -- summary under Article 4
Income Tax Technical News, No. 35, 26 February 2007, "Treaty Residence- Residence of Convenience"-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ...
Administrative Policy summary
Income Tax Technical News, No. 25, 30 October 2002, "E-Commerce" -- summary under Article 12
Income Tax Technical News, No. 25, 30 October 2002, "E-Commerce"-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 ...
Administrative Policy summary
84 C.R. - Q.58 -- summary under Article 13
.- Q.58-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 guidelines re principal derivation of value from real estate. ...
Administrative Policy summary
Income Tax Technical News, No. 34, 27 April 2006 under "Delaware Revised Uniform Partnership Act" -- summary under Article 5
Income Tax Technical News, No. 34, 27 April 2006 under "Delaware Revised Uniform Partnership Act"-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Discussion of Toronto Blue Jays Baseball Club v. ...
Administrative Policy summary
93 C.M.TC - Q. 15 -- summary under Article 5
93 C.M.TC- Q. 15-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 RC will use the OECD commentary as an aid in considering whether a wholly-owned subsidiary is an independent agent of its non-resident parent. ...
Administrative Policy summary
7 August 1998 Discussion Paper on Proposed Changes to Revenue Canada's Guidelines for Treaty-Based Waivers of Regulation 105 Withholding (Draft) -- summary under Article 5
7 August 1998 Discussion Paper on Proposed Changes to Revenue Canada's Guidelines for Treaty-Based Waivers of Regulation 105 Withholding (Draft)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...
Administrative Policy summary
31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613) -- summary under Article 5
31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 RC refers to the 1992 OECD Commentary in considering whether there is a permanent establishment in Canada. ...
Administrative Policy summary
22 March 1990 Memorandum (August 1990 Access Letter, ¶1397) -- summary under Article 5
22 March 1990 Memorandum (August 1990 Access Letter, ¶1397)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Finance supports the principle set out in the OECD Commentaries respecting the determination of permanent establishment on the basis of available space. ...
Administrative Policy summary
IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada" -- summary under Article 4
IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Discussion of limited liability corporations in para. 10 of Appendix A. ...