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.-- 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. ...

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

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. ...

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. ...

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. ...

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. ...

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. ...

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. ...