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Canada (National Revenue), 2016 FC 1086-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 CRA reasonably considered that TD Securities did not apply where the dividend was not fully and comprehensively taxed in the U.S. ...

In the course of dismissing the application of the applicants, Bell J addressed the exemptions claimed for correspondence or documents obtained by the Canadian competent authority under the Tax Information Exchange Agreement with Bermuda and the Income Tax Conventions with Ireland, the Netherlands and the U.S. ...

Canada (National Revenue), 2013 DTC 5110 [at at 6090], 2013 FC 572-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 After the taxpayer's U.S. parent (TeleTech US) determined that it had undercharged the taxpayer for administrative services provided in 2000-2002, TeleTech US filed amended returns with the IRS to increase its taxable income for those years, and the taxpayer requested CRA (on May 5, 2004) to make a corresponding downward adjustments for those years- which was withdrawn in March 2006 in order to clear the way for a request made of CRA (on May 11, 2006) under Art. ...

Stankovic, 2018 FC 462-- summary under Subsection 231.1(1) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1) a taxpayer with an unreported Swiss bank account was not yet under criminal investigation In 2009, the French authorities obtained the Falciani List (on which an HSBC employee in Switzerland had copied account holder information) and pursuant to Art. 26 of the Canada-France Convention provided information to CRA showing inter alia that the taxpayer had a large HSBC account in Switzerland. ...