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Canada- Israel Development Ltd. v. MNR, 85 DTC 718, [1985] 2 CTC 2460 (TCC) -- summary under Article 24

MNR, 85 DTC 718, [1985] 2 CTC 2460 (TCC)-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 taxes paid by a controlled foreign affiliate treated as tax paid by the Cdn shareholder The taxpayer, a Canadian resident corporation, owned all the shares of an Israeli corporation (“CAN-IS”) that received a dividend from another Israeli corporation (“ICL”) that was not a foreign affiliate of CAN-IS. ... Section 2 of the Protocol to the Treaty provided: Nothing in this Convention shall be construed as preventing Canada from imposing tax on amounts included in the income of a resident of Canada according to section 91 of the Canadian Income Tax Act... ...

Retfalvi v. USA (2019), No. 18-2158 (U.S.C.A., 4th Circuit) -- summary under Article 26A

., 4th Circuit)-- summary under Article 26A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26A Art. 26A of the Canada-U.S. ... Convention. Retfalvi paid this amount in 2016, but filed a refund claim with the IRA, which was denied, and brought a refund suit. ...

Vincent v. Agence du revenu du Québec, 2020 QCCQ 3605 -- summary under Article 7

Agence du revenu du Québec, 2020 QCCQ 3605-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 use of the firm’s Quebec establishments imputed to a “silent” partner, who had departed from KPMG Canada to France, in ousting a Quebec-France Treaty exemption From 2001 to May 2012, the taxpayer (“Vincent”), who was a lawyer and a Quebec resident, was a partner of KPMG Canada. ... Article 14 of the Income Tax Convention between France and Quebec only exempted income derived by a resident of France from a “liberal profession” (such as law) where such income did not relate to a fixed base used by the French resident in Quebec in exercising such profession. ...

Marin v. The Queen, 2022 TCC 49 -- summary under Article 24

The Queen, 2022 TCC 49-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. 23 of French Treaty inapplicable where income of a particular taxation year was not otherwise taxed twice France started imposing income tax on rental income as it was earned rather than the tax being payable one year in arrears, as previously. ... The Tax Convention refers to income, regardless of when the tax is to be paid to or collected by the tax authorities. … Thus, since Mr. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2 -- summary under Article 12

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 restrictions on concept of royalty payment Before noting (at para. 110) that the OECD commentary on the wording of Art. 12 of the Model Convention supported a narrow view of the scope of immovable property in Art. 6, Lady Rose stated (at para. 109): Article 12(4) [of the Canada-UK Treaty] defines "royalties" as any payment received "as a consideration for the use of, or the right to use, any copyright, patent, trade mark... ...

10 January 1990 T.I. (June 1990 Access Letter, ¶1281) -- summary under Article 12

(June 1990 Access Letter, ¶1281)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 The definition of royalties in the Canada-U.S. Income Tax Convention includes payments made to a resident of the U.S. for the use of computer software. ...

3 March 1997 Internal T.I. 9641327 - SUBSECTION 20(11) AND TAX TREATIES -- summary under Article 24

3 March 1997 Internal T.I. 9641327- SUBSECTION 20(11) AND TAX TREATIES-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Discussion of the interaction of s. 20(11) and paragraph 5 of Article XXIV of the U.S. Convention. ...

13 September 1995 Internal T.I. 9518087 - GAINS IN U.S. TREATY & LIFE INSURANCE PROCEEDS -- summary under Article 13

TREATY & LIFE INSURANCE PROCEEDS-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The word "gains" in article XIII of the Canada-U.S. Convention means capital gains. ...

12 June 2009 External T.I. 2009-0316511E5 F - Charges sociales et autres retenues France -- summary under Article 18

12 June 2009 External T.I. 2009-0316511E5 F- Charges sociales et autres retenues France-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 list of pension plans recognized for French tax purposes re Art. ... XXIX(5) of the Canada-France Convention: [or as non-business income tax for the purposes of section 126]: CSG ("contribution sociale généralisée" ["general social contribution"]) CRDS ("contribution pour le remboursement de la dette sociale " [contribution for the repayment of the social debt]) Sécurité sociale vieillesse [old age social security] (retirement) Pole emploi (similar, in your opinion, to Employment Insurance) Retraite complémentaire [supplementary pension] (according to you, mandatory)? ... XXIX(5), CRA stated: [T]he purpose of this provision of the Convention is to oblige a contracting country (in your example, Canada) to grant relief during the first 60 months of residence to an individual who contributes to a pension fund in his or her country of origin (France) while working in the country where he or she resides (Canada) and continues during this period to contribute to the pension fund in his or her country of origin. ...

2010 Ruling 2010-0353101R3 - Article IV(7)(b) Restructuring -- summary under Article 4

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. ...

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