Search - convention

26 November 2013 CTF Roundtable, 2013-0507961C6- Article XXIX-A LOB provisions-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A listed company with multiple classes; meaning of "substantial;" dividends to bankrupt; base erosion test Q. 5(a) Super-voting shares Where a company has multiple classes of voting shares, with one or more of the classes thinly traded or not at all, each class of shares should be considered separately when determining whether those shares are "primarily and regularly traded" for purposes of Art. ... Convention. A ruling request for such a company with a class of super-voting shares was withdrawn when CRA expressed its concern on this issue. ...

LLPs and LLLPs-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Florida and Delaware LLPs and LLLPs treated like LLCs Are Florida and Delaware LLPs and LLLPs that are treated by CRA as corporations considered to come within para. ...

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 RRSPs and RCAs not treated as flow-through entities under Art. ...

11 October 2013 Roundtable, 2013-0492821C6 F- Question 3- APFF Round Table-- summary under Section 4.3 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 4.3 s. 4.3 precludes application of tie-breaker rule After noting the introduction of s. 4.3, CRA stated: [T]he effect of this new provision is to make it impossible to break the tie [under the Canada-U.S. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

28 May 2015 IFA Roundtable Q. 2, 2015-0581551C6- IFA 2015 Q.2: GAAR and treaty shopping-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 What is CRA's position on the application of the GAAR to treaty shopping arrangements? ...

5 October 2012 Roundtable, 2012-0451251C6 F- Excess of foreign tax withheld at source-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose tax withheld in excess of Treaty-rate is not deductible as an expense Tax is systematically withheld on income from ADRs at above the maximum rates permitted by the conventions. ...

28 May 2015 IFA Roundtable Q. 12, 2015-0581521C6- IFA 2015 Q.12: Canada-Switzerland Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 resolution of conflicting French and English Treaty versions of Swiss Treaty in taxpayer's favour A corporation resident in Switzerland ("Swissco") wholly-owns "Holdco," which wholly-owns "Canco"). ...

17 June 2004 IFA Roundtable Q. 2, 2004-0072381C6- Flow-through treaty benefits partnership-- summary under Article 1 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 1 CRA is revisiting the issue whether a partner resident in a treaty country should receive the benefits of a tax treaty between Canada and that treaty country where the partner is a member of a partnership formed in Canada which is transparent for Canadian tax purposes but is considered to be a foreign corporation for purposes of the treaty country's tax system, so that the partners are not actually taxable on the partnership income in the treaty country. ...