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XII, para. 4(a) of the Canada-France Convention are satisfied. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

9 September 2004 External T.I. 2004-007035-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. ...

27 April 2012 External T.I. 2011-0429361E5- India non-resident activities in Canada-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 marketing in Canada through unrelated corp A corporation resident in India which engages in residential development in India and does not have an office in Canada would likely not have a permanent establishment in Canada by virtue of engaging an unrelated Canadian corporation ("Canco") to advertise in Canada for the sale of Indian condos and provide interested parties with information, with Canco (which does not have authority to conclude contracts) directing parties who are still interested to contact the Indian corporation directly. ...

6 August 2004 External T.I. 2004-0066621E5- Irish Investment Undertakings-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Irish investment undertakings not Treaty residents Three entities (a unit trust, investment company and limited partnership) which were certified by the Irish Revenue Commissioners to be investment undertakings which were resident in Ireland for income tax purposes and thereby subject to Irish tax legislation were found not to be resident under the new Treaty as they were not subject to comprehensive taxation in Ireland (i.e., they currently were not chargeable to Irish tax on their income). ...

2008 Ruling 2008-0272141R3- Conversion of Delaware corporation into LLC-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 disposition of tcp through U.S. holdco was exempted The shares of a U.S. corporation (D Co) holding two Canadian subsidiaries (G Co and H Co) whose shares are taxable Canadian property are contributed by its U.S. ...

12 March 2013 External T.I. 2013-0476351E5- Taxation of Roth IRA-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 election available to defer taxation on Roth IRA income A Roth IRA is not a registered plan under the ITA, but Article XVIII will generally apply to distributions to a Canadian resident individual out of a Roth IRA if the distribution would be excluded from income tax if paid to a US resident. ...

3 February 2014 External T.I. 2012-0464541E5- Article 15 of the Canada-Germany Income Tax Treaty-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 183-day test One of the components of the safe-harbour rule in Art. 15(2)(a) of the Canada-Germany Treaty is that the employee is present in Canada for a period or periods not exceeding in the aggregate 183 days in any 12 month period commencing or ending in the fiscal year. ...

28 May 2015 IFA Roundtable Q. 2, 2015-0581551C6- IFA 2015 Q.2: GAAR and treaty shopping-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 What is CRA's position on the application of the GAAR to treaty shopping arrangements? ...