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Alternative Minimum Tax")-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Discussion of double taxation situation where a U.S. citizen who is resident in Canada and earning only Canadian-source income is subject to U.S. alternative minimum tax. ...

.- Q.4-- summary under Paragraph 250(1)(a) Summary Under Tax Topics- Income Tax Act- Section 250- Subsection 250(1)- Paragraph 250(1)(a) A U.S. resident who sojourns in Canada for 183 days or more will be required to report his world income, will be entitled to deduct amounts exempted by the Convention, and will be entitled to claim full personal exemptions. ...

.- Q. 29-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A payment to a non-resident for the use of, or the right to use, a custom computer software program for a period of indefinite duration is subject to tax under s. 212(1)(d)(i). ...

IC 87-2 "International Transfer Pricing and Other International Transactions", para. 32-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Most treaties do not require that management fees be treated as anything other than a component of industrial, commercial or business profits. ...

Situation D-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Revenues 4.9:1 1.6:1 13.5:1 0.5:1 Assets 5.6:1 1.1:1 21.0:1 0.5:1 # of Employees 4.0:1 1.6:1 38.8:1 0.1:1 To date… Rulings has not denied the availability of treaty benefits under Article XXIX-A(3) on the determination that the US business was not substantial in comparison to the Canadian activities. ...

.- Q. 40-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 alienation under US treaty includes deemed dispositions RC accepts the interpretation of "alienation" contained in the Treasury Department's technical explanation, which refers to deemed dispositions under the domestic law. ...

Convention. ...

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Section 28 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 28 Includes Example 120 (the provision of lighting and other special effects at a gala event event in Quebec is considered to be services performed at the convention centre where the gala takes place). ...

93 C.M.TC- Q. 11-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 If a resident of a non-treaty country owning computer software rights licences them to residents of Canada "via" a Dutch corporation to take advantage of the exemption in the new protocol, the exemption in the new protocol will not apply if the interposed Dutch corporation is not the beneficial owner of the royalty payments. ...

IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Where an individual is present in Canada for a period not exceeding 60 days and is not entering Canada on a recurring basis, RC will not consider the individual to have a fixed base in Canada for purposes of administering the various treaties. ...