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5 October 2012 Roundtable, 2012-0451251C6 F- Excess of foreign tax withheld at source-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose tax withheld in excess of Treaty-rate is not deductible as an expense Tax is systematically withheld on income from ADRs at above the maximum rates permitted by the conventions. ...

CRA also indicated that neither Article 11 nor Article 17 of the Canada-UK Convention would apply to relieve taxation. ...

Convention. ...

17 October 2012 External T.I. 2011-0428781E5- US LLC owned by Canadian residents-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 U.S. ...

28 May 2015 IFA Roundtable Q. 12, 2015-0581521C6- IFA 2015 Q.12: Canada-Switzerland Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 resolution of conflicting French and English Treaty versions of Swiss Treaty in taxpayer's favour A corporation resident in Switzerland ("Swissco") wholly-owns "Holdco," which wholly-owns "Canco"). ...

28 July 2015 External T.I. 2014-0522271E5- REIT Distribution- Article 21 Canada-Sweden Treaty-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Treaty rate on REIT distributions to Swedish resident An income distribution by a Canadian REIT to a Swedish resident was subject to a reduced rate of Part XIII witholding of 15% pursuant to Art. 21, para. 2 of the Canada-Sweden Treaty. ...

XIX, para. 1 of the Convention with France. CRA indicated that, with her net income being lower than his, he could not claim child care expenses as “only the spouse or common-law partner with the lowest net worldwide income (including nil income) can generally deduct these expenses.” ...

15 August 1997 External T.I. 9711265- RESIDENCE OF SICAVS-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Sociétés d'investissement à capital variable are not considered by RC to be residents of a contracting state as they are not liable to taxation in their own right. ...

22 March 1994 Internal T.I. 9402046- CENTRE OF VITAL INTERESTS- XXXXXXXXXX EMPLOYEE (4093- U5-100-4)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Where a taxpayer has not severed his residential ties with Canada, RC must analyze the personal and economic ties over a period of time in order to make a determination of those more meaningful or significant ties. ...

18 March 1996 External T.I. 9600675- treaty residence- barbados insurance companies-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 A foreign affiliate incorporated in Barbados and licensed under the Exempt Insurance Act, 1983 will not be considered to be "liable to taxation" in Barbados given that its main and, most likely, source of income will effectively be exempt from taxation in Barbados for a guaranteed period of 30 years with the exception of amounts, which although expressed as an income tax, in substance represent an annual licence fee of Bds. $5,000. ...