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Convention, assuming the lender is a U.S. resident. ...

Income Tax Convention, the Canadian-resident shareholder of an S-Corp will not obtain a Canadian foreign tax credit for the U.S. tax paid by him in respect of the income of the S-Corp unless he had income from other sources of the United States that was subject to Canadian income tax. ...

17 July 1992 T.I. 920168 (January- February 1993 Access Letter, p. 35, ¶C180-134)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Whether an arrangement under which the U.S. seller assigned its receivables, or nominated a U.S. bank as its agent to collect the receivables, gave rise to a change in beneficial ownership of the interest on the receivables could only be determined after an examination of the relevant documentation. ...

(Tax Window, No. 6, p. 7, ¶1361)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 An individual is resident of Canada for 15 years or more (paragraph 9) if he is a resident of Canada for discrete periods aggregating 15 years and each consisting of at least 12 consecutive months. ...

15 November 1990 TI 902937-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Interest on a borrowing by a U.S. resident to acquire a rental property in Canada would be subject to Canadian withholding tax if the rental property was a rental business, as the interest would be borne by a permanent establishment in Canada and, therefore, would arise in Canada, thereby giving Canada the right to tax the interest under s. 212(13.2) of the Act. ...

(Tax Window, No. 27, p. 17, ¶2329)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A U.K. citizen who is resident in Canada for 20 years, then resident in the U.K. for seven years, before he sells a U.K. real property in respect of which he had made an election under s. 48(1)(c) upon ceasing to be a resident in Canada, will be exempt from tax on the disposition pursuant to Article XIII(8). ...

20 August 2007 External T.I. 2005-0111151E5- Article 13(4) Canada- Germany Tax Agreement-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 full-service motel would not be a rental property "Real property would not be considered rental property for purposes of Article 13(4) of the [Canada-Germany] Treaty unless the property was subject to a lease agreement that created a landlord/tenant relationship... ...

13 July 2009 External T.I. 2009-0318701E5- Article X(2) and Tiered Partnerships-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Where a US corporation that is a qualifying person is a 99.99% limited partner of a Delaware limited partnership which, in turn, is a 99.99% limited partner of a second Delaware limited partnership which owns all the shares of Canco, the US corporation will be considered to have an "ownership interest" in Canco, so that it will be entitled to the 5% rate on dividends paid by Canco. ...

(Tax Window, No. 1, p. 18, ¶1169)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Where a tax-exempt organization is a member of a partnership which has been subject to Part XIII tax on income payments received by it, RC on application of the exempt partner will refund the difference between the pro rata share of the Part XIII tax and the amount which would have been withheld if the exempt partner had received the income directly. ...

(Tax Window, No. 12, p. 17, ¶1559)-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 Where a taxable Canadian corporation leases a ship on a bare boat basis from a corporation resident and managed in the Netherlands, Part XIII tax will be payable on any lease payments relating to voyages made principally for the purpose of transporting passengers or goods between Canadian ports; and the lease payments for other voyages will be exempt. ...