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4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...

28 November 2011 CTF Roundtable, 2011-0425901C6- Does share derive value principally from real prop-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 whether shares derive their value from real property is determined irrespective of debt allocation After the questioner referenced the previous position that, in the context of Treaty references to shares deriving in their value principally from real property, CRA would accept a valuation method that assigned the debt of a company to the assets to which the debt reasonably related, CRA stated: In the context of tax treaties...the determination whether a share of a company derives its value principally from real or immovable property situated in Canada should be made by reference to the value of the properties of the company without taking into account its debts or other liabilities. ...

16 June 2014 Internal T.I. 2014-0527901I7- Public Lending Right Payments under Art. 14-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 public lending right payments not royalties Payments made by the Canada Council under the public lending rights program, i.e., payments to Canadian authors in order to compensate them for the free access to their works in Canadian libraries "would be in respect of their independent literary or artistic activities" rather than (royalty) "payments… made in consideration for the use of, or the right to use, the work being lent out (or their copyright in the work)," so that in the case of a resident of Ireland receiving a PLRP payment, that payment would be taxable in Canada only to the extent that the author has a fixed base in Canada for the purposes of performing their "professional services" and only to the extent the PLRP can be attributed to that fixed base. ...

.-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 SIFT distributions respected as dividends An IRA account of Mr. ...

18 June 2013 Internal T.I. 2011-0393451I7- Treaty Exemption- Fixed Base available in Canada-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 A non-resident of Canada who was resident in Ireland for purposes of the Canada-Ireland Treaty, worked as an independent contractor, under a short-term contract for service, for a provincial authority at facilities maintained and operated by it. ...

18 June 2013 Internal T.I. 2011-0393451I7- Treaty Exemption- Fixed Base available in Canada-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Dudney folowed A non-resident of Canada who was resident in Ireland for purposes of the Canada-Ireland Treaty, worked as an independent contractor, under a short-term contract for service, for a provincial authority at facilities maintained and operated by it. ...

21 October 2013 External T.I. 2013-0477121E5- FTC and US Expat Regime-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 FTC for 30% US pension withholding A taxpayer who has renounced his US citizenship elects under Code s. 877A to irrevocably waive any right to claim any reduction in withholding on future pension payments under any US treaty and pay a flat 30% US tax on the taxable portion of all future pension payments. ...

XII, para. 4 of the Canada-US Tax Convention would be exempt from Part XIII tax as being for the use of information concerning industrial or commercial experience. ...

22 May 2014 May IFA Roundtable, 2014-0526711C6- Article XXIX-A(3) of the US Treaty-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A tcp gains on U.S. shares derived from Canada under para. 3 UK Parent owns US Parent, which owns US Holdco (whose shares are taxable Canadian property) which owns Can Sub. ...

2014 Ruling 2013-0511761R3- Cross-border financing Canada- USA-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A interest paid to U.S. sister of LLCs carrying on same business eligible under para. 3 ForSub, which is a U.S. ...