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23 May 2013 IFA Round Table, Q. 10-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 interposition of third-country entities not viewed favourably Are there any new issues with respect to Article IV(6) and (7) of the US treaty? ...

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 CASD does not share its APA paper with the taxpayer before submitting it to the other Treaty partner CASD has stopped sharing a copy of its APA paper to the taxpayer for comments before sending it to a treaty partner. ...

Folio S6-F4-C1, "Testamentary Spouse or Common-law Partner Trusts," 3 February 2022-- summary under Article 29B Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29B Application of Art. ...

19 September 2015 STEP Roundtable, Q.4-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 S Corp election Are there circumstances where a request under Art. ...

23 May 2013 IFA Round Table, Q. 10-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 comment on data centre interpretation below Are there any new issues with respect to the services PE provision in the Article V of the US treaty? ...

Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 CRA referred to the travel restrictions imposed by governments or businesses in response to the COVID-19 crisis as a safety measure for their citizens or employees (the “Travel Restrictions”) and to the administrative response of CRA (being a concession rather than an interpretive approach) which will apply from March 16 until June 29, 2020, unless extended. ...

Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 CRA referred to the travel restrictions imposed by governments or businesses in response to the COVID-19 crisis as a safety measure for their citizens or employees (the “Travel Restrictions”) and to the following administrative response of CRA (being a concession rather than an interpretive approach) which will apply from March 16 until September 30, 2020, unless extended. ...

Step 2- Determine the total of: all ITCs you are claiming for purchases of, or improvements to, real property and capital property for use more than 50% in commercial activities, including the deemed tax payable when capital property is brought into a participating province to use in your commercial activities; any ITC on your acquisition of, or improvement to, real property based on its percentage of use in your commercial activity (must be more than 10%) and for which you filed Form GST26, Election or Revocation of an Election by a Public Service Body to Have an Exempt Supply of Real Property Treated as a Taxable Supply, that is effective the day you acquired the property; any ITC equal to the basic tax content of real property just before an election (Form GST26) filed by you takes effect to treat that property as a taxable supply and any ITC on the deemed purchase of that property based on its percentage of use in your commercial activity (must be more than 10%), where the election takes effect on a day other than the day you acquired the property or became a registrant; all ITCs for goods you bought, imported or brought into a participating province that are sold by an agent or an auctioneer acting as your agent; all ITCs for goods you imported on behalf of a non-resident for use exclusively in your commercial activities and sold when you are acting as an agent, or auctioneer and agent for the non-resident person; 60% of the total of the GST/HST adjustments (for example, for price reductions and rebates for foreign conventions, for short-term accommodation in tour packages, and for artistic works produced for export) or of point-of-sale rebates for the provincial part of the HST that the charity gave in the reporting period (no amount should be included for any Ontario First Nations point-of-sale relief credited in the reporting period a the charity may claim this amount by filing Form GST189, General Application for Rebate of the GST/HST, using code 23). all amounts for GST/HST adjustments you gave for tax charged in excess of the GST/HST collectible on certain supplies of property and services; all GST/HST adjustments you gave for tax collected in error or bad debts you wrote off during the period for the sale of real property or capital property; all GST/HST adjustments for new housing rebates you credited during the period; and all ITCs that you were entitled to claim and that you carried forward from a reporting period when you did not have to use this net tax calculation for charities. ...