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2017 Ruling 2017-0712731R3- Amount of withholding tax under paragraph 212(1)(b)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 CRA treats non-resident LPs as conduits for purposes of Treaty interest withholding relief Four non-resident LPs with the same non-resident corporate general partner (GP Co) collectively control Canco through their holdings of a common and preferred shares (with the minority shareholders being unrelated investors) and have also made unsecured interest-bearing loans to Canco. ...

2023 Ruling 2022-0958521R3- foreign absorptive mergers-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 disposition of shares of companies resident in third countries and which were taxable Canadian property was exempted under XIII(4) of the Canada-US Treaty After giving effect to some preliminary transactions, a U.S. corporation which was a qualifying person for purposes of the Canada-US Treaty (the “Treaty”) wholly-owned four stacked corporations in Country 1. ...

2022 Ruling 2022-0929431R3 F- Entity classification-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 French SCPI is a corporation rather than partnership CRA ruled that a société civile de placement immobilier (“SCPI”) [real estate investment company] was a corporation for ITA purposes and a “company” for purposes of the Canadian application of the Convention with France. ...

2012 Ruling 2011-0424211R3- Article X(2) and 84(3) deemed dividends-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Treaty-reduced rate applicable to redemption all of the common shares of a Canadian grandchild held by US beneficial grandparent All of the Class A shares of two taxable Canadian corporations ("OpCo2" and "Salesco") are owned by a corporation ("USSalesco1") which is not fiscally transparent and is resident in the U.S. for purposes of the Canada- U.S. ...

2014 Ruling 2013-0509431R3- Part XIII tax and distributions from a trust-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 distributions to U.S. residents funded out of ROC payments and cross-border interest The Fund is a listed mutual fund trust which is not fiscally transparent for U.S. tax purposes. ...

2014 Ruling 2014-0527221R3- Disposition of shares under Canada-Israel Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 "consist of" not a "derived from" test Current structure Foreign Parent, an Israeli public company, holds its LP interest in LP through a Canadian subsidiary (Canco1) and holds its GP interest through a Canadian subsidiary (Canco1) of an immediate Israeli subsidiary (Foreign Holdco) of Foreign Parent. ...

2014 Ruling 2014-0534751R3- Deemed dividends from ULC holdco and Art IV(7)(b)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 2-step PUC increase and distribution by ULC coupled with dividend paid directly by exchangeable share sub of ULC to U.S. ...

2014 Ruling 2014-0521831R3- Withholding on interest payments-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 interest paid within consolidated U.S. group re acquisition of Cdn hybrid LP is Treaty-exempt Structure US Parent Co, which is a U.S. public corporation and a qualifying person under the Canada- U.S. ...

Convention) will incorporate Canco under Part 2 of the Canada Not-for-profit Corporations Act and become the sole member and grant a non-transferable, non-exclusive licence to Canco to market and sublicense Forco's Custom Software to sub-licensees under an Agreement to sell the Custom Software in Canada. ...

2015 Ruling 2014-0550611R3- Permanent Establishment-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 home of a Canadian employee doing marketing (but no contracting) for a U.S. employer is not a PE of the U.S. employer ForCo’s Canadian business ForCo is a wholly-owned U.S. subsidiary of Foreign Parent, which is a U.S. non-profit organization. ...