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(Tax Window, No. 6, p. 7, ¶1361)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 An individual is resident of Canada for 15 years or more (paragraph 9) if he is a resident of Canada for discrete periods aggregating 15 years and each consisting of at least 12 consecutive months. ...

28 May 2009 Internal T.I. 2009-0319161I7- Canada-US Treaty- Article XXIX A(3)-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A CRA will therefore interpret the term 'registered securities dealer' to mean: a 'registered securities dealer' for the purposes of the Income Tax Act (Canada); or a 'dealer in securities' for the purposes of Section 475 of the Internal Revenue Code and whose dealings as such are regulated under US federal or state-level securities legislation. ...

2006 Ruling 2006-0173601R3- Permanent establishment-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A representative office of a foreign bank whose activities were restricted to the general promotion in Canada of the foreign bank's products and services, and acting as a liaison between Canadian customers (or potential customers) and the foreign bank, would be considered to be engaged in activities of a preparatory or auxiliary nature and, therefore, would not be considered to be a permanent establishment under the applicable Treaty. ...

15 November 1990 TI 902937-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Interest on a borrowing by a U.S. resident to acquire a rental property in Canada would be subject to Canadian withholding tax if the rental property was a rental business, as the interest would be borne by a permanent establishment in Canada and, therefore, would arise in Canada, thereby giving Canada the right to tax the interest under s. 212(13.2) of the Act. ...

(Tax Window, No. 27, p. 17, ¶2329)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A U.K. citizen who is resident in Canada for 20 years, then resident in the U.K. for seven years, before he sells a U.K. real property in respect of which he had made an election under s. 48(1)(c) upon ceasing to be a resident in Canada, will be exempt from tax on the disposition pursuant to Article XIII(8). ...

14 October 1992 Rulings Tax Seminar Central Region 9230057-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 "We would definitely recommend that the Department challenge any arrangement where a Canadian distributor supposedly enters into an agreement with a non-resident person to acquire the right to produce or reproduce video tapes and then turns around and enters into another contract with the same non-resident, or a person related or connected to that non-resident, to have the video tapes reproduced by such a person. ...

20 August 2007 External T.I. 2005-0111151E5- Article 13(4) Canada- Germany Tax Agreement-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 full-service motel would not be a rental property "Real property would not be considered rental property for purposes of Article 13(4) of the [Canada-Germany] Treaty unless the property was subject to a lease agreement that created a landlord/tenant relationship... ...

Convention rather than Article XIV, it is RC's administrative practice to permit fees paid to a non-resident director for services rendered in Canada to be withheld at the flat rate of 15% specified in Regulation 105. ...

Convention rather than Article XIV, it is RC's administrative practice to permit fees paid to a non-resident director for services rendered in Canada to be withheld at the flat rate of 15% specified in Regulation 105. ...

13 July 2009 External T.I. 2009-0318701E5- Article X(2) and Tiered Partnerships-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Where a US corporation that is a qualifying person is a 99.99% limited partner of a Delaware limited partnership which, in turn, is a 99.99% limited partner of a second Delaware limited partnership which owns all the shares of Canco, the US corporation will be considered to have an "ownership interest" in Canco, so that it will be entitled to the 5% rate on dividends paid by Canco. ...