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Situation D-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Revenues 4.9:1 1.6:1 13.5:1 0.5:1 Assets 5.6:1 1.1:1 21.0:1 0.5:1 # of Employees 4.0:1 1.6:1 38.8:1 0.1:1 To date… Rulings has not denied the availability of treaty benefits under Article XXIX-A(3) on the determination that the US business was not substantial in comparison to the Canadian activities. ...

.- Q. 40-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 alienation under US treaty includes deemed dispositions RC accepts the interpretation of "alienation" contained in the Treasury Department's technical explanation, which refers to deemed dispositions under the domestic law. ...

Convention. ...

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Section 28 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 28 Includes Example 120 (the provision of lighting and other special effects at a gala event event in Quebec is considered to be services performed at the convention centre where the gala takes place). ...

93 C.M.TC- Q. 11-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 If a resident of a non-treaty country owning computer software rights licences them to residents of Canada "via" a Dutch corporation to take advantage of the exemption in the new protocol, the exemption in the new protocol will not apply if the interposed Dutch corporation is not the beneficial owner of the royalty payments. ...

IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Where an individual is present in Canada for a period not exceeding 60 days and is not entering Canada on a recurring basis, RC will not consider the individual to have a fixed base in Canada for purposes of administering the various treaties. ...

Convention are both applicable, the payer is required to withhold 10% on the first $5,000 and 15% on the balance. ...

Income Tax Technical News No. 22, 11 January 2002-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 After referring to Dudney, CRA stated: "We do not propose to litigate another case based on the taxpayer's use of space within the premises of another person unless we can reasonably maintain, based on the particular facts, that the taxpayer in fact had sufficient physical control of the space to carry on those aspects of his or her business that are appropriate to the space. ...

Round Table, Q. 2-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) "In a situation where a non-resident of Canada carries out a series of transactions whose purpose is to secure an exemption from or reduction of Canadian tax through a tax convention that Canada has concluded with another country, the Department will examine this type of situation closely in order to establish whether it results in an abuse. ...

5 May 2021 IFA Roundtable, Q.6-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 disclosure of number and nature of cases brought to arbitration is prohibited When asked to disclose statistics on the number of cases that have been brought to arbitration under each of Canada’s tax treaties and to describe the underlying issues, CRA indicated: Pursuant to international agreements, disclosure of such information is not permitted. ...