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12 June 2009 External T.I. 2009-0316511E5 F - Charges sociales et autres retenues France -- summary under Non-Business-Income Tax

CRA responded: By virtue of paragraph 1 of Article XV of the Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. … If the employee performs employment in France while resident in Canada, France may tax the employee to the extent provided in Article XV of the Convention and Canada may allow a foreign tax credit for non-business income taxes paid by the employee to France. … 2002-0169607 states that the "contribution sociale généralisée" and the "contribution pour le remboursement de la dette sociale" qualify as a non-business income tax … since these contributions have the legal characteristics of a tax (levied without direct consideration) as opposed to social contributions which, in turn, confer on those who pay them a right to benefits. … [S]ocial security contributions generally do not qualify as income or profits taxes because they are not really taxes at all, within the judicially accepted meaning of that term. ...

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152) -- summary under Article 22

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Discussion of annual distributions of income by a Canadian- resident trust to a U.S. partnership. ...

17 May 1993 T.I. (Tax Window, No. 31, p. 4, ¶2510) -- summary under Article 4

(Tax Window, No. 31, p. 4, ¶2510)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Tax-exempt entities are resident in the jurisdiction in which they are organized. ...

3 September 1992 T.I. 920333 "Interest-Free Loans - Reason for Withholding" -- summary under Article 10

3 September 1992 T.I. 920333 "Interest-Free Loans- Reason for Withholding"-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 The word dividend in the Canada U.S. ...

6 January 1992 T.I. (Tax Window, No. 15, p. 14, ¶1679) -- summary under Article 7

(Tax Window, No. 15, p. 14, ¶1679)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Re taxability of rental payments derived from the use of moveable property in Canada by a Norwegian limited partnership. ...

Knights of Columbus v. The Queen, 2008 DTC 3648, 2008 TCC 307 -- summary under Article 5

The Queen, 2008 DTC 3648, 2008 TCC 307-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 The taxpayer, a U.S. ...

Szymczyk v. The Queen, 2014 TCC 380 (Informal Procedure) -- summary under Estoppel

Moore, 2005 SCC 38, that "estoppel by convention operates where the parties have agreed that certain facts are deemed to be true and to form the basis of the transaction," and stating (at para. 37) "that estoppel will not apply if an approval given by a tax authority is contrary to law," Woods J rejected the taxpayer's argument that the Minister was estopped from assessing contrary to the 1982 authorization. ...

MIL (Investments) S A v. The Queen, 2006 DTC 3307, 2006 TCC 460, aff'd 2007 FCA 236 -- summary under Subsection 245(3)

This result positioned the taxpayer to clearly fit within an exemption from Canadian capital gains tax under Article XIII of the Canada-Luxembourg Income Tax Convention (the "Treaty") on a subsequent disposition of that block of shares once the taxpayer became resident in Luxembourg. ...

Graves v. The Queen, 90 DTC 6300 (FCTD) -- summary under Income-Producing Purpose

" Conventions of Amway distributors that the taxpayers attended in the United States for the purpose of developing their leadership abilities and for the purposes of developing motivation, enthusiasm and vision were found to have been incurred for an income-producing purpose. ...

Commissioner of Taxation v. Resource Capital Fund III LP, [2014] FCAFC 37 (Fed. Ct. of Austr.) -- summary under Article 13

.)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 mining information not to be valued separately at reproduction cost The appellant ("RCF") was a non-Australian partnership which was assessed on the basis that its gain from the sale of a "member ship interest" in an Australian company ("SBM") with two underground gold mines in Western Australia was from "taxable Australian real property". ...

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