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27 March 2018 External T.I. 2017-0715561E5- Withholding tax on royalties for streamed content-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 television and broadcasting included digital streaming Canco streams movies and TV shows (the “digital content”) to its Canadian and foreign subscribers (who pay monthly fees) through a TV video stream and a digital content library. ...

27 January 2003 External T.I. 2002-0169385 F- Un serveur et l'établissement stable-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Canadian servers of Swiss company would not be a PE if sales of its product not made through the website A Swiss corporation engaged in various countries in selling products and that uses a Canadian subsidiary to promote the products will use Canadian servers for its website, which will provide information on the corporate group in general and will incidentally include information on the Canadian subsidiary. ...

4 April 2019 Internal T.I. 2017-0736531I7- Articles IV(6) and X(6) of the Canada-US Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Art. ...

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 contingent interest under Art. ...

The tax-deferred rollover is not available for amounts which are received on a periodic basis out of the pension plan, nor is it available for amounts for which the recipient has taken a deduction under subparagraph 110(1)(f)(i) due to a specific provision of the Canada-UK Tax Convention. … [but here] no [such] deduction would be available …. ...

26 November 2020 STEP Roundtable Q. 4, 2020-0838001C6- Foreign Tax Credit-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 a capital gain’s geographic source for Canadian FTC purposes was re-sourced to Australia under the Treaty-source rule A Canadian-resident individual (the “Taxpayer”), wholly owns a U.K. ...

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25 November 2021 CTF Roundtable Q. 4, 2021-0912111C6- Liable To Tax & Territorial Taxation-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis- provided its CMC was there Generally, a person must be “liable to tax” in a contracting state to be a resident there for treaty purposes. ...

.-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction Where dividends paid by a resident corporation resident to a resident personal discretionary trust are deemed pursuant to s. 104(19) to be received by a beneficiary that is resident, but not domiciled in Barbados (“NR-Beneficiary”), would those dividends be subject to a reduced rate of withholding at 15% pursuant to Arts. ...

XIII(7) Canada-US Treaty and Trusts-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. ...