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13 April 2017 External T.I. 2015-0601781E5- U.S. tax paid in respect of an LLC's income-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Canada's denial of foreign tax credits re undistributed LLC income is consistent with Art. 24 of Canada-US Treaty A Canadian-resident individual who is a member of a U.S. ... In particular, after noting that the OECD Commentary on Art. 23B of the Model Convention “expressly contemplates that states may impose timing restrictions on claiming foreign tax credits,” and that where this is so “these countries…would be expected to seek other ways…to relieve the double taxation which might otherwise arise in [such] cases,” CRA stated: In the case of Canada, such “other ways … to relieve the double taxation” include deductions allowed under subsections 20(11) and 20(12) of the Act. ...

16 June 2020 Internal T.I. 2019-0792651I7- 10(8) of the Canada-UK Tax Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 engaging the “one of the main purposes” test in Art. 10(8) of the Canada-UK Treaty for accessing reduced withholding resulted in a 25% withholding rate Art, 10(8) of the Canada-U.K. Convention provides: The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment. ...