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Leopoldo Parada, "Agents vs. Commissionnaires: A Comparison In Light of the OECD Model Convention", Tax Notes International, October 7, 2013, p. 59 -- summary under Article 5

Commissionnaires: A Comparison In Light of the OECD Model Convention", Tax Notes International, October 7, 2013, p. 59-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 What is a commissionaire arrangement? ...

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607 -- summary under Article 19

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 19 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 19 Only cases where taxes have been charged are covered (p. 611) Under the wording of article 19(l)(a) of the MLI, only cases where taxes have actually been charged can be submitted to arbitration…. ...

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607 -- summary under Article 20

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 20 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 20 Nature of specific case mutual agreement procedure under OECD Model (p. 609) Once the taxpayer has filed an application for a specific case MAP under article 25(1) of the OECD Model … [t]he procedure…consists of two stages. ...

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607 -- summary under Article 28(2)

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 28(2) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 28- Article 28(2) Arbitration reservations are subject to other CTA party’s acceptance (p. 611) Article 28(2)(a) permits the parties to the MLI to formulate one or more reservations with regard to the scope of cases that should be eligible for arbitration under Part VI. ...

Kingsett & OPB/Primaris -- summary under Unsolicited Bids

US tax consequences If Primaris has made an election to be classified as a partnership for Code purposes, non-resident holders receving distributions from Primaris that are subject to Canadian withholding tax may be denied the benefit of reduced rates under the Canada-US Convention as a result of Art. IV(7)(b) of the Convention. Subject to the PFIC rules, a US unitholder will realized a capital gain or loss on a disposition of units pursuant to the Offer based on the difference the US-dollar value of the Canadian dollars received pursuant to the Offer and the adjusted tax basis of the units. ...

S5-F1-C1 - Determining an Individual’s Residence Status -- summary under Article 4

S5-F1-C1- Determining an Individual’s Residence Status-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 1.41 [T]o be considered liable to tax for the purposes of the Residence article of Canada's tax treaties, an individual must be subject to the most comprehensive form of taxation as exists in the relevant country. ... The OECD Model Tax Convention states in part, as follows: "…the permanence of the home is essential; this means that the individual has arranged to have the dwelling available to him at all times continuously, and not occasionally for the purpose of a stay which, owing to the reasons for it, is necessarily of short duration (travel for pleasure, business travel, educational travel, attending a course at a school, etc). ... [T]he commentary to paragraph 2 of the Residence article of the OECD Model Tax Convention, which states in part, as follows: "If the individual has a permanent home in both Contracting States, it is necessary to look at the facts in order to ascertain with which of the two States his personal and economic relations are closer. ...

S5-F2-C1 - Foreign Tax Credit -- summary under Business-Income Tax

Convention), the foreign tax must be levied on net income (but not necessarily as would be computed under the Act) unless it is similar to Part XIII tax (para. 1.7). ...

S5-F2-C1 - Foreign Tax Credit -- summary under Non-Business-Income Tax

Convention), the foreign tax must be levied on net income (but not necessarily as would be computed under the Act) unless it is similar to Part XIII tax (para. 1.7). ...

Timbercreek -- summary under Cross-Border REITs

Interest on any note owing by Holding GP to the Fund should not be subject to US withholding tax provided that the Fund unitholders are able to establish that such interest is exempt under the Canada-US Convention or under the portfolio interest exemption. ...

Pengrowth/WEF -- summary under Litigation trust distribution

Non-Residents A dividend, such as the Dividend, paid or credited or deemed to be paid or credited to a Non-Resident Holder will be subject to Canadian withholding tax at the rate of 25%, subject to any reduction in the rate of withholding to which the Non-Resident Holder is entitled under any applicable income tax convention. ...

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