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25 January 2010 Internal T.I. 2009-0319951I7- Article 15 & definition of permanent establishment-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 PE to be determined under treaty of residence of employee rather than employer ACo is a British company that performed seismic surveys offshore Canada. ... BCo had a permanent establishment in Canada pursuant to Art. 21- Offshore Activities of the Canada-Norway Tax Convention. ...

13 November 2009 Internal T.I. 2009-0318491I7- Article IV(6)/IV(7) 'Same Treatment'-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 interest paid by ULC to its U.S. corporate shareholders is not subject to IV(7)(b) if the ULC is a partnership for Code purposes ...

Convention. ...

28 May 2009 Internal T.I. 2009-0319161I7- Canada-US Treaty- Article XXIX A(3)-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A CRA will therefore interpret the term 'registered securities dealer' to mean: a 'registered securities dealer' for the purposes of the Income Tax Act (Canada); or a 'dealer in securities' for the purposes of Section 475 of the Internal Revenue Code and whose dealings as such are regulated under US federal or state-level securities legislation. ...

3 September 1997 Internal T.I. 9714337- STOCK OPTION BENEFIT EXERCISED BY A NON-RESIDENT-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 The benefit realized by a resident of the U.S. on the exercise of an employee stock option was not taxable in Canada because he was not present in Canada for more than 183 days in the year and the stock option benefit received by him was not deductible by the employer in computing its income. ...

22 March 1994 Internal T.I. 9402046- CENTRE OF VITAL INTERESTS- XXXXXXXXXX EMPLOYEE (4093- U5-100-4)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Where a taxpayer has not severed his residential ties with Canada, RC must analyze the personal and economic ties over a period of time in order to make a determination of those more meaningful or significant ties. ...

20 March 2002 Internal T.I. 2002-0126537- Article XV(2); Employee Stock Options-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 A U.S. resident employee of a Canadian corporation was paid salary of $7,000 by it and granted stock options in respect of which he ultimately realized a benefit of $543,500. ...

25 February 2014 Internal T.I. 2013-0475161I7- Whether USCo has a PE in Canada-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 offsite project services re mooted Canadian construction site p.e., separate "enterprise" and "connected project" under Art. ... Convention apply when the services are not rendered at the building site or construction or installation project, and does it apply to "intellectual" services? ...

5 November 2015 Internal T.I. 2013-0496401I7- XXIX-A(3)- Active Trade or Business Exception-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A connection test in XXIX-A(3) of U.S. ... Convention that the Interest Payments be income be derived "from the other Contracting State (Canada) in connection with…that (US) trade or business" met based on a "funding approach"? ...

A portion of the PLF applicable to training services would otherwise have been caught by s. 212(1)(d)(iii) before giving effect to their exemption under Articles XI(4) and VII of the Canada-US Convention. ...