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Results 971 - 980 of 1132 for convention

Markovitz, "Permanent Establishment - Home Office Relations", International Tax Planning, 1996 Canadian Tax Journal, Vol. 44, No. 4, p. 1127. -- summary under Article 7

.-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 ...

Richard G. Tremblay, "Canada-U.S. Treaty Fifth Protocol: Binding Arbitration", Canadian Current Tax, Vol. 18, No. 11, p. 1, August 2008 -- summary under Article 26

Treaty Fifth Protocol: Binding Arbitration", Canadian Current Tax, Vol. 18, No. 11, p. 1, August 2008-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 Discussion of Annex A. ...

D. Sandler, J. Li, "The Relationship between Domestic Anti-Avoidance Legislation and Tax Treaties", 1997 Canadian Tax Journal, Vol. 45, No. 5, p. 891. -- summary under Article 3

.-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 ...

J. David Oliver, "Beneficial Ownership", Bureau for International Fiscal Documentation, Vol. 54, No. 7, July 2000, p. 310. -- summary under Article 11

.-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 ...

Brian Cleave, "The Treaty Residence of Trusts in the United Kingdom and Canada: Some Thoughts on the Smallwood and Garron (or St Michael Corp) Cases", British Tax Review, 2011, No. 6. p. 705. -- summary under Article 4

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

Bradley A. Sakich, "Inbound Personal Services", 1996 Conference Report, c. 44 at 44:8-10 -- summary under Article 15

Sakich, "Inbound Personal Services", 1996 Conference Report, c. 44 at 44:8-10-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 Discussion of meaning of "borne by" and of decision in C.I.R. v. ...

Susan Wooles, "Cross-border Employees: a Doubly Taxing Matter", Taxation of Executive Compensation and Retirement, Vol. 22, No. 4, November 2010, p. 1343 -- summary under Article 15

Susan Wooles, "Cross-border Employees: a Doubly Taxing Matter", Taxation of Executive Compensation and Retirement, Vol. 22, No. 4, November 2010, p. 1343-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 Includes discussion as to whether a US subsidiary is a contructive employer of a seconded Canadian employee; and whether employee loan-outs give rise to a services permanent establishment. ...

Lanthier, "Acquiring, Holding and Financing Canadian Corporations", Bulletin for International Fiscal Documentation, Vol. 48, No. 8/9, August/September 1994, Special IFA issue, p. 419. -- summary under Article 13

.-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Discussion of "Canadian spider" structure. ...

Greg S. Lindsay, "U.S. Investment in Canadian Resource Property: Recent Developments", International Tax Planning, Vol. XVI, No. 3, 2011, p. 1120 -- summary under Article 13

XVI, No. 3, 2011, p. 1120-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Includes discussion of exclusions in immovable property definition in Luxembourg and Netherlands treaties; and treaty shopping. ...

Dewling, "U.S. Residents Rendering Temporary Services in Canada May Be Subject to Canadian Tax on Remuneration Received from U.S. Employer", Taxation of Executive Compensation and Retirement, November 1990, p. 355. -- summary under Article 15

.-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 ...

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