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Administrative Policy summary
Income Tax Technical News, No. 34, 27 April 2006 under "Delaware Revised Uniform Partnership Act" -- summary under Article 5
Income Tax Technical News, No. 34, 27 April 2006 under "Delaware Revised Uniform Partnership Act"-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Discussion of Toronto Blue Jays Baseball Club v. ...
Administrative Policy summary
93 C.M.TC - Q. 15 -- summary under Article 5
93 C.M.TC- Q. 15-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 RC will use the OECD commentary as an aid in considering whether a wholly-owned subsidiary is an independent agent of its non-resident parent. ...
Administrative Policy summary
7 August 1998 Discussion Paper on Proposed Changes to Revenue Canada's Guidelines for Treaty-Based Waivers of Regulation 105 Withholding (Draft) -- summary under Article 5
7 August 1998 Discussion Paper on Proposed Changes to Revenue Canada's Guidelines for Treaty-Based Waivers of Regulation 105 Withholding (Draft)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...
Administrative Policy summary
31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613) -- summary under Article 5
31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 RC refers to the 1992 OECD Commentary in considering whether there is a permanent establishment in Canada. ...
Administrative Policy summary
22 March 1990 Memorandum (August 1990 Access Letter, ¶1397) -- summary under Article 5
22 March 1990 Memorandum (August 1990 Access Letter, ¶1397)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Finance supports the principle set out in the OECD Commentaries respecting the determination of permanent establishment on the basis of available space. ...
Administrative Policy summary
IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada" -- summary under Article 4
IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Discussion of limited liability corporations in para. 10 of Appendix A. ...
Administrative Policy summary
91 C.R. - Q.1 -- summary under Article 10
.- Q.1-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 A U.S. corporation holding shares through a U.S. partnership will not be eligible for the 10% rate. ...
Administrative Policy summary
1 May 1991 Memorandum (Tax Window, No. 3, p. 25, ¶1228) -- summary under Article 11
1 May 1991 Memorandum (Tax Window, No. 3, p. 25, ¶1228)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Discussion of modification to position contained in 4 September 1990 memorandum. ...
Administrative Policy summary
93 C.M.TC - Q. 11 -- summary under Tax Benefit
93 C.M.TC- Q. 11-- summary under Tax Benefit Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(1)- Tax Benefit Where a non-resident of Canada enters into a series of transactions designed primarily to secure an exemption or reduction from Canadian tax under an income tax convention, RC may seek to apply the general anti-avoidance rule to deny any tax benefit that such transactions would otherwise produce. ...
Administrative Policy summary
IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999 -- summary under Article 7
IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Where the treaty does not contain a specific article on management or administration fees, such fees paid to the non-resident will, to the extent they are reasonable, be considered to be covered by the business profits article. ...