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Technical Interpretation - Internal summary

5 October 2021 Internal T.I. 2021-0903361I7 - Remittance Basis Taxation - Canada-Barbados Treaty. -- summary under Article 29

.-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction Where dividends paid by a resident corporation resident 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. ...
Technical Interpretation - Internal summary

3 February 2022 Internal T.I. 2021-0922301I7 - Art. XIII(7) Canada -US Treaty and Trusts -- summary under Article 24

XIII(7) Canada-US Treaty and Trusts-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. ...
Technical Interpretation - Internal summary

21 October 2021 Internal T.I. 2020-0872281I7 - S.219 and Article X(6) of the Canada-US Treaty -- summary under Article 10

21 October 2021 Internal T.I. 2020-0872281I7- S.219 and Article X(6) of the Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 different treatment of losses under Pt. ...
Technical Interpretation - Internal summary

23 November 2023 Internal T.I. 2020-0850381I7 - Article V(4) of the Canada-U.S. Treaty -- summary under Article 5

Treaty-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time Art. ...
Technical Interpretation - Internal summary

14 December 2015 Internal T.I. 2014-0558661I7 - Application of Article V(9) to a partnership -- summary under Article 5

14 December 2015 Internal T.I. 2014-0558661I7- Application of Article V(9) to a partnership-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 services PE of U.S. partnership based on collective Canadian activities of all partners Mr. ...
Technical Interpretation - Internal summary

15 February 2023 Internal T.I. 2022-0925731I7 - Qualified donee - Article XXI of Canada-US Treaty -- summary under Article 21

15 February 2023 Internal T.I. 2022-0925731I7- Qualified donee- Article XXI of Canada-US Treaty-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Art. ...
Technical Interpretation - Internal summary

13 October 2023 Internal T.I. 2019-0819351I7 - Barbados Treaty Limitation Period -- summary under Article 9

13 October 2023 Internal T.I. 2019-0819351I7- Barbados Treaty Limitation Period-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 limitation period under the Canada-Barbados Treaty did not preclude CRA from making a transfer-pricing increase to the profits of the Canadian parent Transactions between a corporation resident in Canada (“Canco”) and its wholly-owned subsidiary resident in Barbados (“BarbadosCo”) were not on the terms that would have prevailed between arm’s length persons. ...
Technical Interpretation - Internal summary

18 April 2019 Internal T.I. 2018-0753621I7 - Subsection 247(12) -- summary under Article 4

18 April 2019 Internal T.I. 2018-0753621I7- Subsection 247(12)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. ...

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