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(Tax Window, No. 32, p. 6, ¶2598)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A sales force in Canada could be regarded as stable or permanent activities of a U.S. corporation in Canada. ...

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Re taxation of a U.S. charitable organization's share of dividends received by a U.S. partnership from a Canadian resident corporation. ...

(February 1990 Access Letter, ¶1124)-- summary under Section 255 Summary Under Tax Topics- Income Tax Act- Section 255 Neither section 255 of the Act, nor section 5 of the Income Tax Conventions Interpretation Act, are relevant to the interpretation of the "in Canada" requirement in s. 127(9). ...

No. 2, p. 4, ¶1047)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 In the case of a corporation incorporated in Canada and having its place of effective management in The Netherlands, Canada will not agree that the corporation is a resident of The Netherlands in the absence of evidence that Canadian tax is not being avoided. ...

T.I. 921585 (December 1992 Access Letter, p. 24, ¶C111-048)-- summary under Article 19 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 19 A Canadian citizen who is employed at the Canadian embassy in Washington will be subject to tax in Canada even after he has acquired U.S. citizenship. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that a German open-end real estate fund would be treated as a resident of Germany for purposes of Article 4 of the German Treaty. ...

20 February 2003 External T.I. 2002-014360-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 A s. 20(12) deduction may not be taken by a U.S. citizen resident in Canada on the withholding from U.S. source property income that is in excess of a rate of 10% and less than a 15% rate. ...

LLPs and LLLPs-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Florida and Delaware LLPs and LLLPs treated like LLCs Are Florida and Delaware LLPs and LLLPs that are treated by CRA as corporations considered to come within para. ...

13 November 2009 Internal T.I. 2009-0318491I7- Article IV(6)/IV(7) 'Same Treatment'-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 interest paid by ULC to its U.S. corporate shareholders is not subject to IV(7)(b) if the ULC is a partnership for Code purposes ...

21 December 2009 External T.I. 2009-0330491E5- Article XXI Exemption-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 IV(7)(b) of Canada-U.S. ...