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19 May 2010 Roundtable, 2010-0366531C6- Canada-United States Tax Convention Unedited CRA Tags Paragraph 78(1)(b) of the Act; Article IV(6) of the Convention Principal Issues: Whether Article IV(6) of the Convention could apply to an amount deemed to be paid pursuant to paragraph 78(1)(b) of the Act Position: Yes Reasons: See response International Fiscal Association Annual Conference May 19, 2010 Application of Article IV(6) of the Canada-US Tax Convention to Paragraph 78(1)(b) Deemed Payments Assume that a Canadian corporation ("Canco") is wholly-owned by a United States limited liability corporation ("LLC"). ... Tax Convention (1980) (the "Treaty"). The LLC is disregarded under the taxation laws of the United States and, therefore, is fiscally transparent for the purposes of Article IV(6) of the Treaty. ...

16 June 1991 External T.I. 9113055 F- Canada-Italy Income Tax Convention Unedited CRA Tags 2(1), 126(1), 126(7) non-business income tax, Treaty Italy 5-911305 Dear Sirs: Re:  Canada-Italy Income Tax Convention This is in reply to your letter of May 7, 1991 wherein you requested our views on the income tax liabilities of a Canadian resident in the following hypothetical situation as outlined in your letter. ... X is employed in Italy by an employer that does not have a permanent establishment (within the meaning of Article V of the Canada-Italy Income Tax Convention Act,1980 (the "Tax Treaty") or other fixed base in Canada. 3.      ...

27 July 1990 Ruling 901351 F- Canada-Australia Income Tax Convention on Capital Gains Unedited CRA Tags n/a   July 27, 1990 International Audits Division Rulings Directorate   G. ... Calderwood (613) 957-2126 Director   901351     SUBJECT:  24(1) Canada-Australia Income Tax Convention This is in reply to your Memorandum dated June 18, 1990 whereby you requested our opinion as to whether residents of Australia are exempt from Canadian tax liability in respect of capital gains realized on the disposition of taxable Canadian property, particularly shares in the capital stock of a corporation resident in Canada (other than a public corporation), by virtue of the Canada-Australia Income Tax Convention (1980) (the "Treaty"). ...

Income Tax Convention Unedited CRA Tags n/a 24(1) 900875   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9246 August 30, 1990 Dear Sirs: Re:  Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your reply to your letter dated May 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

Income Tax Convention- Mine and Mill Unedited CRA Tags 7(b) 5-8648 Dear Sirs: Re: Article 13 of the Canada-United Kingdom Income Tax Convention (the "Treaty") This is in reply to your letter dated August 31, 1989 whereby you requested our opinion concerning the application of paragraph 7(b) of Article 13 of the Treaty to a mine and a mill.  ...

22 January 1990 Internal T.I. 59107- Convention du 17 décembre 1984 Unedited CRA Tags n/a 19(1) Your File No. 98308-007   Our File No. 5-9107   A. Lebeau   (613) 957-4363 Le 22 janvier 1990 Maître, Objet:  24(1) 19(1) Convention du 17 décembre 1984 La présente fait suite à vos lettres du 6 et 16 novembre 1989 requérant le bureau principal de reconsidérer sa position du 8 septembre 1989 relativement au sujet mentionné ci-dessus. ...

Income Tax Convention-Withholding Tax on RRIF Payments Unedited CRA Tags 212(1)(q) 19(1) File No. 5-9689   Maureen Shea-DesRosierss   (613) 957-8953 April 4, 1990 Dear Sirs: Canada-U.S. Income Tax Convention ("U.S. Treaty") Withholding Tax on Payments Made under a Registered Retirement Income Fund ("RRIF") This is in reply to your letter of February 28, 1990 concerning the applicable withholding tax rate to payments made under an RRIF to a resident of the United States. ...

8 January 2004 External T.I. 2003-0049781E5- Article IV of the Canada-US Convention Unedited CRA Tags 212(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2003-004978 January 8, 2004 Dear Sir: Re: Article IV of the Canada-United States Income Tax Convention We are writing in response to your correspondence of November 20, 2003 concerning Article IV of the Canada-United States Income Tax Convention (the "Treaty") to a U.S. trust ("UST") in the following situation: 1. ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Unedited CRA Tags Article XXX(3) of the Canada-Barbados Treaty Principal Issues: Under the Insurance Act (Barbados), a Class 2 licence entitles the company to insure third-party risks wherever situated. ... Reasons: See below. 2023 IFA Annual Conference CRA Roundtable Question 4- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ...

12 February 2010 External T.I. 2010-0355661E5- Article IV(6) of the Canada-US Tax Convention Unedited CRA Tags Canada-US Tax Convention Article IV(6); Fifth Protocol Article 27(2)(b) Principal Issues: Where a US resident corporation derives business income through a US Limited Liability Company (USLLC), which entity's taxable year is relevant when considering the coming into force provision in subparagraph 2(b) of Article 27 of the Fifth Protocol? ... Tax Convention This is in response to your email dated January 25, 2010 regarding the application of paragraph IV(6) of the Canada-United States Tax Convention ("the Treaty") in the context of the facts given below. 1. ...