Search - convention

Canada, 2017 FCA 3-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 a Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income At issue was whether Art. ...

This result positioned the taxpayer to clearly fit within an exemption from Canadian capital gains tax under Article XIII of the Canada-Luxembourg Income Tax Convention (the "Treaty") on a subsequent disposition of that block of shares once the taxpayer became resident in Luxembourg. ...

Canada (Attorney General), 2022 FCA 117-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 taxpayer stonewalling satisfied the Swiss exchange-of-information requirement that CRA had “pursued all reasonable [domestic] means available” The resident applicants (principally Messrs. ...