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3 February 2014 External T.I. 2012-0464541E5- Article 15 of the Canada-Germany Income Tax Treaty-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 183-day test One of the components of the safe-harbour rule in Art. 15(2)(a) of the Canada-Germany Treaty is that the employee is present in Canada for a period or periods not exceeding in the aggregate 183 days in any 12 month period commencing or ending in the fiscal year. ...

CRA also indicated that neither Article 11 nor Article 17 of the Canada-UK Convention would apply to relieve taxation. ...

Convention. ...

17 October 2012 External T.I. 2011-0428781E5- US LLC owned by Canadian residents-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 U.S. ...

28 July 2015 External T.I. 2014-0522271E5- REIT Distribution- Article 21 Canada-Sweden Treaty-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Treaty rate on REIT distributions to Swedish resident An income distribution by a Canadian REIT to a Swedish resident was subject to a reduced rate of Part XIII witholding of 15% pursuant to Art. 21, para. 2 of the Canada-Sweden Treaty. ...

XIX, para. 1 of the Convention with France. CRA indicated that, with her net income being lower than his, he could not claim child care expenses as “only the spouse or common-law partner with the lowest net worldwide income (including nil income) can generally deduct these expenses.” ...

15 August 1997 External T.I. 9711265- RESIDENCE OF SICAVS-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Sociétés d'investissement à capital variable are not considered by RC to be residents of a contracting state as they are not liable to taxation in their own right. ...

18 March 1996 External T.I. 9600675- treaty residence- barbados insurance companies-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 A foreign affiliate incorporated in Barbados and licensed under the Exempt Insurance Act, 1983 will not be considered to be "liable to taxation" in Barbados given that its main and, most likely, source of income will effectively be exempt from taxation in Barbados for a guaranteed period of 30 years with the exception of amounts, which although expressed as an income tax, in substance represent an annual licence fee of Bds. $5,000. ...

Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Although in most cases comparing gross asset values will be the simpler (and perhaps quite often the most reasonable) method for making the 50 percent determination respecting whether a share derives its value principally from Canadian real property, depending on the facts and circumstances of a particular situation other valuation methods such as the net asset value method may be appropriate. ...

Convention would exempt from Canadian tax the profits of a U.S. resident's Canadian branch operations derived from point-to-point cross-border motor vehicle delivery of passengers or properties but intra-Canada profits would be subject to tax under s. 115(1)(a)(ii) of the Act. ...