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15 May 2019 IFA Roundtable Q. 2, 2019-0798751C6- Shared workspaces and PE-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 a Canadian shared-work space can readily constitute a PE In the following examples, will a U.S. resident carrying on business in Canada, be considered to be a permanent establishment (“PE”) in Canada, assuming Arts. ...

15 May 2019 IFA Roundtable Q. 8, 2019-0798841C6- Active Trade or Business Test under the LOB Clause-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Art. ...

3 December 2019 CTF Roundtable Q. 2, 2019-0824381C6- Foreign taxes paid-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 US and UK Treaties do not eliminate FTC requirement that the taxes be paid Art. ...

15 September 2020 IFA Roundtable Q. 4, 2020-0853391C6- IFA 2020 Q4: Impact Covid-19 on CRA procedures-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 COVID-19 has not changed Treaty time limitations Respecting the pandemic effect on various CRA international programs, CRA indicated: APA and MAP program operations have gradually resumed, and CRA is in contact with its treaty partners using virtual tools such as teleconferencing and, where possible, video-conferencing. ...

7 October 2022 APFF Roundtable Q. 7, 2022-0942731C6 F- Permanent establishment and teleworking-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 having an employee, with general authority to contract, telework from his cottage in another province does not necessarily create an employer PE there Mr. ...

29 November 2022 CTF Roundtable Q. 4, 2022-0950561C6- Servers/Data Centres and Location of Services Rendered-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 remote customer-support services from the US did not cause a Canadian services PE Canco licensed software of a US affiliate (USco), which it used to provide data analytics services to its Canadian customers. ...

29 November 2022 CTF Roundtable Q. 7, 2022-0951051C6- Permanent Establishment and Mining Activities-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 where a UK company remotely operated crypto-mining equipment located on a Canadian host company’s premises, the equipment constituted a Canadian PE Hostco owned Canadian real estate that it used to host crypto-mining equipment owned (or leased) by a UK company (UKco). ...

After indicating that the PPT had supplanted Art. 10(8), CRA noted: Example E in para. 182 of the 2017 OECD Commentary on Art. 29 of the Model Convention describes the similar situation of a shareholder who is slightly below the threshold for access to the lower dividend rate, and who acquires shares for the purpose of taking advantage of the reduced rate. ...

15 May 2024 IFA Roundtable Q. 1, 2024-1007651C6- Principal purpose test and the UK-Canada Tax Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 marginally increasing a shareholding to access the Treaty-reduced rate likely would not engage the PPT A UK-resident corporation increased its voting shareholding of Canco the day before a dividend was paid so as to hold 10% of the shares. ...

Tax Treaty-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A gain of US resident from disposition of Cdn subsidiary’s shares can be considered to be from a connected business Regarding whether Canadian-source income has been derived by a U.S. resident in connection with an active trade or business in the U.S., CRA stated: 1)... ...