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3 February 2016 External T.I. 2014-0548111E5- U.S. tax paid in respect of an LLC's income-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Treaty sourcing rule does not trench on domestic FTC Mr. ...

15 May 2017 External T.I. 2016-0645891E5 F- Services rendered to a State-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 public-sector nurse did not provide services “to Switzerland” for purposes of Art. 18(2)(a) of the Canada-Swiss Treaty Art. 18(2)(a) of the Canada-Swiss Treaty provides that “pensions paid by, or out of funds created by, Switzerland or a political subdivision or a local authority thereof to any individual in respect of services rendered to Switzerland or subdivision or local authority thereof in the discharge of functions of a governmental nature shall be taxable only in Switzerland.” ...

You may find useful information for calculating the portion of the income and expenses of the business carried on in Canada in the Commentary on Article 7 of the 2008 OECD Model Tax Convention. ...

You may find useful information for calculating the portion of the income and expenses of the business carried on in Canada in the Commentary on Article 7 of the 2008 OECD Model Tax Convention. ...

If this occurs, since at least one of the partners of LP is a Canadian resident and the interest is paid to a U.S. person, Part XIII tax is exigible, unless such payment is exempt from Canadian taxation under a provision of the Act (such as subparagraph 212(1)(b)(vii)) or the Convention. ...

12 December 2023 External T.I. 2021-0881541E5- Pension benefit from Chile-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 an exceptional COVID-related withdrawal from a Chilean pension plan qualified as an exempted pension under the Canada-Chile Treaty The Chilean government, in response to the pandemic, adopted an exceptional measure (the “Measure”) in 2020, permitting the withdrawal of up to 10% of the pension savings in the individual pension accounts managed by the Pensions Funds Administrators (“AFP”) in Chile. ...

6 December 2023 External T.I. 2017-0735631E5- Distribution of funds from an IRA and 401(k)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 a Canadian resident may access the Art. ...

The XXXXXXXXXX Order was issued pursuant to paragraph 5(1)(g) of the FMIOA and provides that XXXXXXXXXX officials have in Canada the privileges and immunities set out in Article V of the UN Convention. ...

12 February 2014 External T.I. 2013-0486931E5- Distribution by ULC to a Trust to a NR beneficiary-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 hybrid trust holding ULC Trust is resident in Canada, is not subject to s.75(2), has one individual beneficiary (the "Non-resident Beneficiary") who is a a qualifying person for the purposes of the Canada-U.S.Treaty, and is the sole-shareholder of a Canadian-resident unlimited liability company. ...

31 May 2013 External T.I. 2013-0486011E5- Loan to non-resident- Part XIII tax-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 partnership fiscally transparent for Treaty withholding purposes re s. 15(2) loan made by it A Canadian-resident corporation (CanCo1) and its wholly-owned Canadian-resident subsidiary (CanCo2) are the 99% limited partner and 1% general partner, respectively, of CanLP. ...