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2007 Ruling 2006-0211991R3- Part XIII Tax-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 bareboat charter not giving rise to PE in Canada Transactions Foreign Co, a Norwegian limited liability company, entered into the Agreement for the bareboat charter to it of the Ship from a Norwegian partnership (Partnership IX), and entered into the Contract for the time charter of the Ship to Canadian resident companies (the “Cancos”) for use of the Ship in relation to a facilities located in Canada and owned by the Cancos. ...

Where the individual's services are exclusively performed in Canada, the entire benefit will be sourced to Canada based on the allocation method set out in Annex B to the 5th Protocol to the Canada-US Convention. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. 24(5) of US treaty a complete code for US citizens A U.S. citizen is required to pay U.S. tax on dividends and capital gains at a 20% rate (increased from the previous 15% rate). ...

16 June 2014 Internal T.I. 2014-0525961I7- ON Tax and Brazilian Tax Sparing-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Brazilian tax-sparing rules operate independently of s. 126 Was tax deemed to have been paid (a "tax spared amounts") under Art. 22, para. 3 of the Canada-Brazil Treaty eligible for a foreign tax credit (an "ON FTC") under s. 34(1) of the Taxation Act, 2007 (Ontario) ("the TA")? ...

CTF 2012- Q.10 US LLC-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 LLC not entitled to Treaty benefits except under IV.6 As CRA is not in agreement with the decision in TD Securities (which, in any event, involved pre-5th Protocol timeframes). ...

17 October 2012 External T.I. 2012-0438671E5- Treatment of German social security pension-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Discussion of treatment of German social security pensions including link to discussion at www.cra-arc.gc.ca/tx/nnrsdnts/ntcs/grmny2005-eng.html. ...

5 October 2012 Roundtable, 2012-0451251C6 F- Excess of foreign tax withheld at source-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax foreign withholdings on American depositary receipts in excess of Treaty-limited rate does not qualify as an income tax Tax is systematically withheld on income from ADRs at above the maximum rates permitted by the conventions. ...

20 November 2014 Internal T.I. 2014-0539631I7- Restrictive Covenants-Part XIII (Luxembourg)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 restrictive covenant payment not eligible for relief under Lux Treaty After CanCo had sold shares of a partly-owned subsidiary (SubCo), it made a payment to the other share vendor (LuxCo) pursuant to what was assumed to be a "restrictive covenant" in a related agreement, and withheld and remitted 25% of the payment. ...

XV of Canada-France Convention, as not being in respect of employment exercised in Canada, or Art. ...

23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 non-application of Art. 12 of US Treaty to resource royalties Mr. ...