Search - convention

In the event that the multilateral convention on implementing Pillar One, Amount A is adopted, then the national DST will be removed, and CRA will be prepared to adjust its filing and compliance requirements accordingly. ...

26 May 2016 IFA Roundtable Q. 9, 2016-0642131C6- Article IV(7) and S-Corporations-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 US-Treaty benefits denied on interest paid by a transparent ULC sub to an S-Corp US Parent, which has elected to be treated as an “S-corporation,” so that it is fiscally transparent for Code purposes and its shareholders are taxable in respect of its income, owns all the shares of US Sub, which has elected to be treated as a “Qualified Subchapter S Subsidiary” and also is fiscally transparent for Code purposes. ...

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 contingent interest under Art. ...

26 November 2020 STEP Roundtable Q. 4, 2020-0838001C6- Foreign Tax Credit-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 a capital gain’s geographic source for Canadian FTC purposes was re-sourced to Australia under the Treaty-source rule A Canadian-resident individual (the “Taxpayer”), wholly owns a U.K. ...

25 November 2021 CTF Roundtable Q. 4, 2021-0912111C6- Liable To Tax & Territorial Taxation-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis- provided its CMC was there Generally, a person must be “liable to tax” in a contracting state to be a resident there for treaty purposes. ...

17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 whether employee’s home office can constitute a PE of US employer 50 of the 1,000 employees of USco (a US C-Corp and a “qualifying person” for purposes of the Canada-US Treaty) are Canadian residents who are allowed, but not required, to work from home for two or three days a week. ...

4 June 2024 STEP Roundtable Q. 11, 2024-1003491C6- Foreign Tax Credit for US Estate Tax-- summary under Article 29B Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29B application of Art XXIX-B(6)(a) of the Canada-US treaty where s. 70(5) gain realized on US public company shares and US realty A Canadian resident who was not a U.S. citizen was subject on death to U.S. estate tax on U.S. situs property, namely, US real property and shares of a U.S. public corporation that were not “U.S. real property interests” – and also realized a gain pursuant to ITA s. 70(5). ...

27 October 2020 CTF Roundtable Q. 5, 2020-0864281C6- Article IV:6 of the Canada-US Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 where Canco is held by fiscally transparent Franceco, which is held by LP with only some US partners, there is a choice as to which Treaty to apply A U.S. resident owns a French entity (that is fiscally transparent for U.S., but not Canadian or French purposes) that earns Canadian-source dividends and interest. ...

17 May 2023 IFA Roundtable Q. 6, 2023-0964351C6- Application of the Canada-US Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Treaty benefits could be created for a s. 216 structure by creating partnerships for US purposes Base Case A US corporate REIT that is a qualifying person under the Canada-US Treaty owns US LLC 1, which owns US LLC 2 which, like US LLC 1, is disregarded for US purposes, and is a s. 216 taxpayer. ...

17 May 2023 IFA Roundtable Q. 7, 2023-0964521C6- Application of Article 10, Canada-Hong Kong-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 violating main purpose test in HK Treaty increases dividend rate/ PPT object and purpose test not violated by using personal holding company in same jurisdiction Two individuals (Mr. and Mrs. ...