Search - convention

CONVENTION- CAPITAL GAINS-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 The distribution to a U.S. ... Convention, including any portion of the gain attributable to exchange rate fluctuations. ...

2007 Ruling 2007-0248021R3- Cdn Japan Convention: withholding rate deemed div.-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 a dividend deemed to be received by significant Japanese corporate shareholder of a Canadian corporation under s. 84(3) on the purchase for cancellation y the Canadian corporation of shares held by the shareholder was eligible for the treaty-reduced rate of 5% under the Canada-Japan Convention. ...

2012 Ruling 2011-0416821R3- Article XII of Canada-US Tax Convention-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 sales-related payments for designs needed to manufacture a product exempted under 3(c) of the Canada-US Treaty A "qualifying person" resident of the US ("Pubco") provides Canco with an exclusive licence to distribute two products in Canada, one of which (the "Existing Product") had been manufactured by Canco's US parent, and a second "New Product" that Canco will have a third party manufacture for sale by it. ... Convention. ...

2007 Ruling 2005-0149681R3- Article XXI of Canada-US Tax Convention-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Activities undertaken in Canada, including through leased premises, that related primarily to fund raising would not constitute a business of the U.S. exempt organization. ...

2012 Ruling 2012-0435211R3- Article XXIX-A(3) of the Canada-US Tax Convention-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Holdco, which had been a listed U.S. company, was taken private by L5, which was a fund whose members are not known. ...

2012 Ruling 2012-0435211R3- Article XXIX-A(3) of the Canada-US Tax Convention-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A US Holdco in Chap. 11 receives dividend Holdco, which had been a listed U.S. company, was taken private by L5, which is a fund whose members are not known. ...

30 November 1996 Ruling 9729263- TRUST DISTRIBUTIONS TO NON-RESIDENT BENEFICIARIES-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Ruling that where income of a Canadian trust was distributed to a U.S. partnership, then subject to Article XXIXA of the Canada-U.S. Income Tax Convention, the provisions of that Convention would apply to a partner's share of the partnership income derived from the distributing trust. ...

2010 Ruling 2010-0353101R3- Article IV(7)(b) Restructuring-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ULC PUC increase through stock dividend If a ULC is prohibited from increasing its paid-up capital, it will instead declare and pay a stock dividend of additional common shares having full paid-up capital, with the number of its common shares thereafter immediately being consolidated, and cash being distributed as a paid-up capital distribution on the common shares. ... IV.7(b) of the US Convention did not apply to this transaction (or the alternative transaction entailing a paid-up capital increase), there was a statement that: Notwithstanding that the payment of the stock dividend...will be treated as a taxable dividend under the Act, the integration of the payment of the stock dividend and the subsequent share consolidation will result in no income, profit or gain arising or being recognized under the taxation laws of the United States. Similarly, no amount of income, profit or gain would arise or be recognized under the taxation laws of the United States as a result of those transactions if Canco ULC Amalco were not fiscally transparent under the taxation laws of the United States for the purpose of the Convention. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ... XII(3)(a) of the Convention. The exclusion in that provision for "payments in respect of motion pictures," was not discussed (presumably because it was accepted not to be applicable- see 2011-0374421E5). ...

2003 Ruling 2003-0044063- Residency, France-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that Mr. X is a resident of France under the Canada-France Tax Convention given that he is liable to tax on worldwide income in France, his permanent home is in France (where his family now is), and his home in Canada is rented to arm's length third parties so that it is not available to him or his family. ...