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., 2009 DTC 5721, 2009 FCA 57-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 The taxpayer paid dividends to its shareholder, ("Prévost Holding"), a Netherlands holding company which, in turn, paid dividends in substantially the same amount to its two corporate shareholders, a Swedish and UK corporation. ...

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. ...

The King, 2023 TCC 167-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 a securities loan between residents of two Treaty countries did not change the beneficial ownership of the transferred shares Before a Canadian public corporation (“Husky”) paid a dividend on its shares, two significant shareholders of Husky resident in Barbados (the “Barbcos”) transferred their shares under agreements styled as securities lending agreements to related companies resident in Luxembourg (the “Luxcos”). ...

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. ...