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Glicklich, "International Taxation of Internet Transactions", International Tax Report, May 1996, p. 1. -- summary under Article 5

.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...

Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3. -- summary under Article 24

.-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 ...

Elio Andrea Palmitessa, "Italian Supreme Court Applies the Beneficial Ownership Clause to Pure Holding Companies", Tax Notes International, April 17, 2017, p. 259 -- summary under Article 10

Elio Andrea Palmitessa, "Italian Supreme Court Applies the Beneficial Ownership Clause to Pure Holding Companies", Tax Notes International, April 17, 2017, p. 259-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Dividend withholding avoidance (p. 259) [A] U.S. corporation owned a holding company in France, which in turn owned an Italian subsidiary. ... Focus instead on autonomy of decision-making (p. 261) Ultimately, the Supreme Court held that beneficial ownership — which can be a key issue in the context of the domestic antiavoidance rules as well as the antiabuse principle of article 31 of the Vienna Convention on the Law of Treaties — should be tested, considering the nature and the functions of the direct recipient of income concerning its ability to make autonomous decisions regarding and exercise power over the funds. ...

Nathan Boidman, "How Will Revised Sourcing Rules Affect Sales of U.S.-Made Goods Abroad?", Tax Notes International, 10 February 2020, p. 655 -- summary under Article 7

", Tax Notes International, 10 February 2020, p. 655-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Treaty-limits on what Canada may tax on sales by U.S. into Canada (p.658) Under the prior version of Code s. 863, the gross revenue of a U.S. person from goods produced by it in the U.S. and sold outside the U.S. could often be allocated partly to the other country for U.S. foreign tax credit (FTC) purposes. ... CRA “Canada – US Tax Convention – Agreement between Competent Authorities on the Interpretation of Article V11 (Business Profits)”, (June 26, 2012). ...

Faizal Valli, "Implications of Canadians Transferring a U.S. Retirement Plan to Canada", Taxation of Executive Compensation and Retirement, Vol. XV, No. 2, 2011, p. 930. -- summary under Article 18

.-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 ...

Heather O'Hagan, "Canada-U.S. Tax Treaty Protocol - United States Kicks Off Ratification Process", CCH International Tax, No. 41, p. 1, August 2008 -- summary under Article 4

Tax Treaty Protocol- United States Kicks Off Ratification Process", CCH International Tax, No. 41, p. 1, August 2008-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ...

John Avery Jones, "Place of Effective Management as a Residence Tie-Breaker", International Bureau of Fiscal Documentation Bulletin, January 2005, p. 20. -- summary under Article 4

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ...

Brad Gordica, Sara McCracken, "Canada-US Protocol: Top Five Issues fro Cross-Border Businesses", 2009 BC Conference Report -- summary under Article 4

Brad Gordica, Sara McCracken, "Canada-US Protocol: Top Five Issues fro Cross-Border Businesses", 2009 BC Conference Report-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ...

Jacques Sasseville, "Agency Relationship: When Is There a Permanent Establishment?", International Bureau of Fiscal Documentation Bulletin, Vol. 58, No. 5, May 2004, p. 194. -- summary under Article 5