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Gu v. MNR, 91 DTC 821 (TCC) -- summary under Article 20

MNR, 91 DTC 821 (TCC)-- summary under Article 20 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 20 In order to secure funds required to complete his doctoral program at the University of Toronto, the taxpayer (who was a resident of China) obtained employment at a Toronto law firm. In finding that the taxpayer's employment income was not exempted under Article 19 of the Canada-China Income Tax Convention, Bonner J. stated (p. 824): "The language suggests that the payments must in some way be related to the recipient's maintenance costs, education costs or training costs. ...

Ostime v. Australian Mutual Provident Society (1959), 38 TC 492 (HL) -- summary under Article 7

Australian Mutual Provident Society (1959), 38 TC 492 (HL)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Rule 3 applicable to Case III of Schedule D of the Income Tax Act, 1918 provided that a life insurance company with a head office overseas (in this case, in Australia) should pay tax on a proportion of its world-wide income from investments, determined on the basis of premiums received in the United Kingdom as a percentage of all its premium income. ... -Australia Convention. ...

Columbia Sportswear Co. v. Director of Income Tax, (2015) W.P. No. 39548/2012 (T-IT) (Karnataka High Court) -- summary under Article 5

No. 39548/2012 (T-IT) (Karnataka High Court)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 purchasing office exception included activites to assure quality The petitioner (“Columbia”) was a U.S. ... Primarily at issue was the exclusion, in Art. 5, para. 3(d) of the definition in the India-US Income Tax Convention of “permanent establishment,” for: the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or of collecting information, for the enterprise. The position of the Director of Taxation was that the LO’s activities in India “cannot be said to be an activity solely for the purpose of purchasing the goods or for collecting information for the enterprise” (para. 14), so that such activities (which were viewed as creating a taxable presence for Columbia in India under the Income Tax Law) gave rise to a permanent establishment under the Convention. ...

Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141 -- summary under Article 24

Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 foreign tax credit was not required to be accorded to all the US tax on the gain An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling rights. ... Convention provided: … United States tax paid under the law of the United States and in accordance with this Convention … in respect of income derived from sources in the United States by …a resident of Australia shall be allowed as a credit against Australian tax payable in respect of the income. … Subject to these general principles, the credit shall be in accordance with the provisions and subject to the limitations of the law of Australia as that law may be in force from time to time. ...

30 May 2011 External T.I. 2011-0393731E5 F - Congrès -- summary under Subsection 20(10)

30 May 2011 External T.I. 2011-0393731E5 F- Congrès-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) taxpayer need not be a member of the convention-sponsoring organization Before finding that the annual meeting of the members of the Corporation of Master Pipe Mechanics of Quebec (the "CMMTQ") and the MCEE trade show (Mechanics, Climate control, Electricity and Lighting), of which the CMMTQ is the co-organizer, and which offers, among other things, conventions in which all the members of the industry, whether or not members of the CMMTQ, can participate qualified as conventions, CRA stated: [I]t is not necessary for the taxpayer to be a member of the organization responsible for the convention, but the taxpayer’s presence at the convention must be related to the business the taxpayer carried on or the profession the taxpayer practises. ... Words and Phrases convention ...

6 October 2017 APFF Roundtable Q. 12, 2017-0709111C6 F - Dépenses relatives à un congrès -- summary under Subsection 20(10)

6 October 2017 APFF Roundtable Q. 12, 2017-0709111C6 F- Dépenses relatives à un congrès-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) non-capital convention expenses incurred as business expense may be deducted without refererence to s. 20(10)- but “historically” convention expenses viewed as capital expenditures The two-convention limitation in s. 20(10) applies only to capital expenditures. Are expense of attending conventions which were incurred for earning income from a business not subject to this limitation? ... Historically, the CRA's position with respect to convention expenses is that such expenditures are generally capital expenditures to which paragraph 18(1)(b) applies. ...

11 October 2013 APFF Roundtable Q. 3, 2013-049281 F -- summary under Subsection 94(3)

11 October 2013 APFF Roundtable Q. 3, 2013-049281 F-- summary under Subsection 94(3) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3) Question 3a- Factual dual residency How will CRA apply the tiebreaker rules in the Canada-US Convention in the case of dual residency? ... Question 3b- Deemed dual residency in Canada under s. 94(3) As s. 4.3 of the Income Tax Conventions Act prevails over the Convention, the Convention's tiebreaker rules cannot be applied where s. 94(3) deems a trust to be resident in Canada. ...

2 December 1993 Income Tax Severed Letter 933330A F - Non-Resident Exercises Stock Option (4093-U5-100-15) -- summary under Article 15

Convention denying Canada the right to tax the income deemed to arise on the exercise of the option to him. ... Convention, the calendar year refers to the year in which the employment was exercised and not to the year in which the stock option was exercised. Accordingly, where the stock option benefit relates to a calendar year in which the taxpayer was resident in Canada for a period or periods exceeding 183 days and the taxpayer's remuneration from such employment, including the value of the stock option benefit, exceeded Cdn. $10,000, the Convention would not grant any relief from Canadian taxation. ...

6 June 1994 External T.I. 9335425 - "ALIENATION OF PROPERTY" AND "INCOME" -- summary under Article 13

6 June 1994 External T.I. 9335425- "ALIENATION OF PROPERTY" AND "INCOME"-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A resident of the U.K. will be granted relief from Canadian tax under Article 13, paragraph 8 of the Canada-U.K. Convention on the deemed disposition by her of taxable Canadian property on her death notwithstanding that no income tax will be payable at that time in the U.K. ... Convention will not apply because capital gains arising from a deemed disposition on death are not gains that can remitted or received as referred to in that provision. ...

6 September 2013 External T.I. 2013-0478241E5 - U.K. Individual Savings Account (ISA) -- summary under Article 11

Individual Savings Account (ISA)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Although income earned in a UK Cash ISA is not subject to taxation in the U.K., under the Canadian Income Tax Act ("Act") Canadian residents... must report their worldwide income, including income earned on investments held in the U.K., for Canadian tax purposes. ... CRA also indicated that neither Article 11 nor Article 17 of the Canada-UK Convention would apply to relieve taxation. ... XVIII of the Canada-US Convention.) ...

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