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In the event the Multilateral Convention to implement Pillar One, Amount A, is adopted by the Inclusive Framework on BEPS (IF), it will require national DSTs of participating IF jurisdictions to be removed. ...

Email this Content 25 September 2017 CTF Policy Conference, Morning Finance Session ("Setting the Stage") Maude Lavoie on passive investment income Integration Historical context of current rules No specific proposal yet Reintroduction of Part V Tax Deferred taxation model—apportionment approach Deferred taxation model- elective approach Key questions for discussions Ted Cook on income sprinkling and surplus stripping Income sprinkling Comparison of self-employment, and incorporation/sprinkling Dividends paid to children ages 18-22 Income-sprinkling issue Current sprinkling rules Limitations in current sprinkling rules Policy concern re lifetime capital gains exemption (LCGE) multiplication Policy responses re sprinkling and LTGE Policy Response re LCGE multiplication Sprinkling/LTCG feedback to date Conversion of dividends into capital gains S. 84.1 dividend treatment Avoidance of s. 84.1 Intergenerational business transfers Policy response re surplus stripping Feedback re surplus stripping Andrew Marsland on responses to common misconceptions Income sprinkling Salaries v. dividends Passive income Tax rate on passive investment income Concern over business savings This is a summary of the morning session of the Canadian Tax Foundation Policy Conference, Tax Planning Using Private Corporations: Analysis and Discussion with Finance, Monday, September 25, 2017, Infinity Convention Centre, Ottawa. ...

CRA Response The PPT is set out in article 7(1) of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ...

However, it is our view that those cases essentially deal with treaty interpretation issues in the application of the United Kingdom – United States Tax Convention and that their overall conclusions are not relevant for entity classification in Canada. ...

The same progression of “tie-breaker” tests is found in most of Canada’s treaties as they mirror the tests found in the Organization for Economic Co-operation and Development (“OECD”) Model Tax Convention on Income and on Capital (“Model Treaty”). ...

As mentioned in 2022-0943241E5, pursuant to paragraph 2(3)(b) and subject to the application of an Income Tax Convention with Canada, the non-resident is subject to tax in Canada on its taxable income earned in Canada as determined under section 115. ...