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15 June 2015 External T.I. 2014-0525501E5- Royalty payments & the US or UK Treaties-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 fees paid to the U.S. or U.K. for access to customer lists were exempt royalties Canadian-resident UserCos, who use existing confidential lists of the names and addresses of customers who have purchased certain types of products (“Lists”) for marketing purposes, pay CanCo fees based upon their use of the Lists. ...

7 September 2016 External T.I. 2014-0563781E5- Articles 10 and 11 of Canada-UK Treaty-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 limited partners of an LP can deal at arm’s length with a Canadian subsidiary of the LP A UK corporation (“GP Co”) is the general partner (with a 1% interest) of a UK limited partnership which is fiscally transparent for UK purposes and a partnership for ITA purposes (“UK LP” – all of whose partners are non-residents), and the Limited Partners include LP1 and LP3, which provide benefits under a “recognized pension plan” (as defined in Art. 10, para. 4 of the Canada-UK Treaty) and own 7% and 11% partnership interests, and LP2, a UK corporation owning a 19% partnership interest. ...

7 September 2016 External T.I. 2014-0563781E5- Articles 10 and 11 of Canada-UK Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 limited partners generally do not have control over a company’s voting power/an over-10% limited partner is considered to “indirectly” own over 10% of an LP subsidiary A UK corporation (“GP Co”) is the general partner (with a 1% interest) of a UK limited partnership which is fiscally transparent for UK purposes and a partnership for ITA purposes (“UK LP” – all of whose partners are non-residents), and the Limited Partners include LP1 and LP3, which provide benefits under a “recognized pension plan” (as defined in Art. 10, para. 4 of the Canada-UK Treaty) and own 7% and 11% partnership interests, and LP2, a UK corporation owning a 19% partnership interest. ...

. … [T]he same [would apply] if the Withdrawal took place in a year subsequent to the Taxation Year in which the Deemed Distribution took place … [or] if the Taxpayer was a U.S. citizen, rather than a green card holder, who renounced this US citizenship after becoming a tax resident in Canada … [subject to] subparagraph 4(a) of Article XXIV of the Convention …. ...