Search - convention

5 April 2015 CRA Press Release (respecting Panama Papers)-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 CRA will communicate with Treaty partners to obtain any missing Panama Papers Recent media coverage raises questions about leaked documents from a Panama law firm relating to the offshore financial affairs of numerous individuals worldwide....The Agency is actively pursuing the cooperation of its tax treaty partners and the International Consortium of Investigative Journalists to obtain all of the leaked records that pertain to Canadian residents. ...

TPM-2, on secondary adjustments and repatriation, which is in its final stages of approval, and CRA is working on TPM-3, dealing with downward adjustments, in conjunction with updates to IC 71-17, Guidance on Competent Authority under Canada’s Tax Conventions. ...

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter'- Subsection 237.1(1)-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A sale of shares of USco carrying on parallel business Assume that USco carries on an active business in the United States (other than an investment business). ...

Transfer Pricing Memorandum TPM-06, “Bundled Transactions” 16 May 2005-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 distinction between know-how and services provision After noting the exemption in Art. 12 of the Canada-U.S. ...

23 May 2013 IFA Round Table, Q. 10-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 interposition of third-country entities not viewed favourably Are there any new issues with respect to Article IV(6) and (7) of the US treaty? ...

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 CASD does not share its APA paper with the taxpayer before submitting it to the other Treaty partner CASD has stopped sharing a copy of its APA paper to the taxpayer for comments before sending it to a treaty partner. ...

Folio S6-F4-C1, "Testamentary Spouse or Common-law Partner Trusts," 3 February 2022-- summary under Article 29B Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29B Application of Art. ...

19 September 2015 STEP Roundtable, Q.4-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 S Corp election Are there circumstances where a request under Art. ...

23 May 2013 IFA Round Table, Q. 10-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 comment on data centre interpretation below Are there any new issues with respect to the services PE provision in the Article V of the US treaty? ...

Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 CRA referred to the travel restrictions imposed by governments or businesses in response to the COVID-19 crisis as a safety measure for their citizens or employees (the “Travel Restrictions”) and to the administrative response of CRA (being a concession rather than an interpretive approach) which will apply from March 16 until June 29, 2020, unless extended. ...