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25 January 2010 Internal T.I. 2009-0319951I7- Article 15 & definition of permanent establishment-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 PE to be determined under treaty of residence of employee rather than employer ACo is a British company that performed seismic surveys offshore Canada. ... BCo had a permanent establishment in Canada pursuant to Art. 21- Offshore Activities of the Canada-Norway Tax Convention. ...

2013 Ruling 2012-0471921R3- Deemed dividend on return of capital-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A base erosion test to be satisfied in current year Canco and U.S. ... Income Tax Convention (the "U.S. Treaty"), but is not a qualifying person for purposes of the U.S. ...

26 November 2013 CTF Roundtable, 2013-0507961C6- Article XXIX-A LOB provisions-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A listed company with multiple classes; meaning of "substantial;" dividends to bankrupt; base erosion test Q. 5(a) Super-voting shares Where a company has multiple classes of voting shares, with one or more of the classes thinly traded or not at all, each class of shares should be considered separately when determining whether those shares are "primarily and regularly traded" for purposes of Art. ... Convention. A ruling request for such a company with a class of super-voting shares was withdrawn when CRA expressed its concern on this issue. ...

28 April 2010 External T.I. 2009-0347581E5 F- Frais de formation-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose expense incurred in course of operating real property need not have a direct effect on profit When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible under s. 9 even where there is no direct effect on profits, CRA stated: [I]n order for an expense to be considered to be made or incurred "for the purpose of", it is not necessary to show that income actually resulted from the particular outlay or expenditure itself. ... CRA responded: [W]ith the exception of certain specific provisions … (for example, convention expenses in subsection 20(10) and the restriction on capital cost allowance for rental property in subsection 1100(11) of the Regulations), the Act does not generally provide for a distinction between an expense incurred to earn income from a business and an expense incurred to earn income from property. ...

25 May 2017 External T.I. 2017-0685651E5- Non-capital losses of LLC-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 restriction of s. 88(1.1) to Canadian corporations is not discrimination prohibited by Art. ... XXV(5), CRA noted the statement into para. 41 of the OECD Commentary on Art. 24(3) of the OECD Model Convention that “It does not extend to rules that take account of the relationship between an enterprise and other enterprises (e.g….transfer of losses…,” and stated: [A] rule that effectively allows for the transfer of losses between companies under common ownership does not in our view come within the protection against discrimination found in paragraph 5 of Article XXV... ...