Search - convention

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Barbados remittance-based taxpayer is a Treaty resident under Crown Forest test Where dividends paid by a resident corporation to a resident personal discretionary trust are deemed pursuant to s. 104(19) to be received by a beneficiary that is resident, but not domiciled, in Barbados (“NR-Beneficiary”), would those dividends be subject to a reduced rate of withholding at 15% pursuant to Arts. ...

XIII(7) Canada-US Treaty and Trusts-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 CRA lacks jurisdiction to determine whether a trust can elect under Art. ...

11 April 2023 Internal T.I. 2023-0964101I7- Tax issues for cross-border employees-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 FICA contributions of a cross-border employee are deductible only re employment income from duties physically performed in the US A portion of the employment duties of a cross-border employee (with a hybrid work arrangement) is exercised from Canada in the year but the individual makes contributions under the U.S. ...

. … [T]here is no relief available to a taxpayer under the Canada-Barbados Tax Convention to override the two-year limitation period required by subsection 227(6). ...

7 July 2022 Internal T.I. 2021-0893791I7- Interest expense on subordinated income instrument-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 OECD principles re interest on related-party debt In the early 1980s, Holdco received a ruling as to the deductibility (subject to ITA s. 18(4)) of its interest expense on a 40-year U.S. $15 million debenture (“Debenture”) issued by it to Parent, which bore interest for each year of the lesser of 11% per annum and Holdco’s profits in that year. ...

20 June 2023 Internal T.I. 2021-0904981I7- Application of ss.227(6) to treaty benefits-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 ITA s. 227(6) time limitation applied where “as if resident” clause is silent on the timing of refund claim As an example of an “as if resident” (“AIR”) clause, the Directorate referred to Art. 18(2) of the Canada-Italy Treaty which relevantly indicated that the tax which Canada could impose on a periodic pension arising in Canada does not exceed the lesser of (a) 15% of the excess of the annual pension amount over Cdn.$12,000, and (b) the amount of Canadian tax the recipient would have been required to pay on the annual pension amount had the recipient been resident in Canada. ...

The Directorate indicated that the presentations and exhibitions at the convention were primarily intended to enable participants to acquire new skills, learn about new developments or simply meet people or make themselves known so that, consequently, the expenditures were capital expenditures as they provided a lasting benefit to the manager. ...

26 August 2013 Internal T.I. 2013-0494211I7- participating debt interest-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Cdn petroleum exploration company with no extracted petroleum pays participating interest re price of petroleum Canco, which carries on a business of exploring and developing oil and gas properties in Canada (so that its principal assets consist of rights to explore for and exploit oil and gas), and which does not own any inventory of oil or gas, pays interest to a resident of the US (which is a "qualifying person" within the meaning of Art. ...

20 July 2015 Internal T.I. 2012-0457671I7- Treaty triangulation- Article 15-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 treaty-exemption for remuneration of NR employee employed in deemed offshore drilling PE of employer resident in 2nd treaty county Mr. ...

4 April 2019 Internal T.I. 2017-0736531I7- Articles IV(6) and X(6) of the Canada-US Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Art. ...