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After noting that under the Cananda-France convention, the individual appeared to be entitled to apply to the French government for a refund of the avoir fiscal, CCRA indicated that the full $10,000 gross amount was required to be included in the individual’s income. ...

22 December 2021 External T.I. 2021-0878661E5- Canadian tax on lump sum RRSP payments-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 lump sum RRSP payments to a New Zealand resident are subject to Part XIII tax at a 25% rate Regarding the Canadian withholding tax rate applicable to lump sum payments from a Canadian registered retirement savings plan (“RRSP”) to a resident of New Zealand, the questioner noted that IC76-12R6 as it then read stated, in Appendix C, that a lump sum RRSP payment to a resident of New Zealand was subject to a 15% Canadian withholding tax. ...

6 February 2001 External T.I. 2000-0044095 F- Honoraires- retenue d'impôt non-résident-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 management fees exempted from withholding by business profits article in Canada-US treaty Regarding whether a Canadian resident corporation should withhold tax on fees it pays for services rendered in the United States by individuals resident in the United States, CCRA indicated that, as the Canada-US treaty did not contain a specific article on management or administration fees and those fees were covered by the business profits provisions, a Canadian resident was not required to withhold pursuant to s. 215(1) with respect to the reasonable portion of management fees paid to a U.S. resident who did not have a permanent establishment in Canada. ...

28 June 2010 External T.I. 2009-0329511E5- United States- Dividend Withholding Rate-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A S-Corp a qualified person if meets base erosion test A U.S. resident citizen is the sole shareholder of a U.S. ...

Convention as well as being effectively managed and controlled there, and does not have a permanent establishment in Canada. ...

Income Tax Convention was described as an identifiable location with a certain degree of permanence in which the business of the enterprise is being carried on. ...

10 February 2015 External T.I. 2013-0484501E5- Treaties Article XV-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 $10,000 safe harbour for Canadian employment income of U.S. resident applied on calendar year basis even where he was a part-year resident Part-way through a year an individual ceased to be Canadian-resident and became a U.S. resident but derived employment income from the exercise of his employment in Canada with the same employer throughout that year, of which the portion earned while he was non-resident did not exceed Cdn.$10,000. ...

.-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 REIT income distributions to IRA at 15% An IRA account of Mr. ...

23 October 2012 External T.I. 2012-0440101E5- Article X(6) Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 A US LLC, which has two US-resident members (either two corporations or an individual and a corporation) who qualify for Treaty benefits, carries on business in Canada through a permanent establishment. ...

27 July 2016 External T.I. 2015-0603271E5- Subsection 216.1(1) and permanent establishment-- summary under Article 16 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 16 Art. 16 of US Treaty permits gross withholding taxation even if PE A U.S. ...