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2012 Ruling 2011-0430761R3- Paid-up capital Increase-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 two-step distribution with S-Corp shareholder Canco1 is a Canadian-resident unlimited liability company which is a wholly-owned subsidiary of Parentco, which is a qualifying person for purposes of the Canada-US Income Tax Convention and has elected to be taxed in accordance with subchapter S of Chapter 1 of the Code. ... IV, para. 7(b) of the Convention will not apply. ...

2012 Ruling 2011-0429961R3- Hydrocarbon & Immovable property: Canada-UK Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 storage business carried on in leased real estate had over 50% of value Ruling that the transfer of shares of a UK company (Forco2- whose value is derived from CAnco shares) by two other UK companies (Forco1 and Forco4) would be exempt under Art. XIII, para. 8 of the Canada-UK Convention on the basis of an internal estimate prepared by Canco management that the going concern value of the gas storage business carried on by Canco (which was carried on in real estate facilities held on leased land) was greater than X% of the value of the shares of Canco, and that the hydrocarbon assets of Canco did not exceed Y% of the assets of Canco. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Paragraph 212(4)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(a) management of on-line store 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). ...

2012 Ruling 2012-0432141R3- Server as a permanent establishment-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Canadian data centre The taxpayers (USCo and its indirect subsidiary, NRCo) run various websites and related mobile services in order to gain advertising revenue, and to enable third parties to sell digital content, with one of the taxpayers receiving a percentage of the proceeds. ... Treaty (in the case of USCo) and for purposes of the "Convention" (in the case of NRCo). ...

2012 Ruling 2012-0458361R3- Cross-Border Financing-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A ECo, which is fiscally transparent for U.S. purposes and resident in the U.S. ... Convention), makes a loan (the "Charlie Debt") bearing non-participating interest to CCo, which is a CBCA corporation and affiliated with Eco. ...

2012 Ruling 2012-0458361R3- Cross-Border Financing-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 derivative benefit re loan interest ECo, which is fiscally transparent for U.S. purposes and resident in the U.S. ... Convention), makes a loan (the "Charlie Debt") bearing non-participating interest to CCo, which is a CBCA corporation and affiliated with Eco. ...

For purposes of the application by Canada of the Canada-France Convention, it is a “company” within the meaning of the definition thereof in Art. 3(1)(c) of such Convention. ...

2013 Ruling 2012-0471921R3- Deemed dividend on return of capital-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 PUC increase and distribution Canco and U.S. ... Income Tax Convention (the "U.S. Treaty"), but is not a qualifying person for purposes of the U.S. ...

2013 Ruling 2012-0471921R3- Deemed dividend on return of capital-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A base erosion test to be satisfied in current year Canco and U.S. ... Income Tax Convention (the "U.S. Treaty"), but is not a qualifying person for purposes of the U.S. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that a German open-end real estate fund would be treated as a resident of Germany for purposes of Article 4 of the German Treaty. ...