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22 March 1995 External T.I. 9419185 - WITHHOLDING TAX ON ROYALTIES -- summary under Article 12

22 March 1995 External T.I. 9419185- WITHHOLDING TAX ON ROYALTIES-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Where the Italian branch of a Canadian corporation pays royalties to a German affiliate of the Canadian corporation as the result of the licensing of a trademark by the German affiliate to the Italian branch, withholding tax is exigible by virtue of s. 212(1)(d) of the Act and Article 12 of the Canada-Germany Convention. ...

26 April 1995 External T.I. 9501815 - CAP. GAIN - CANADA-IRELAND TAX AGREEMENT -- summary under Article 13

GAIN- CANADA-IRELAND TAX AGREEMENT-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A resident of Ireland is subject to tax of 15% on the disposition of shares that are taxable Canadian property in light of Article VI of the Canada-Ireland Convention. ...

12 April 1995 External T.I. 9417135 - CANADIAN MUTUAL FUND TRUST-NON-RESIDENT -- summary under Article 22

12 April 1995 External T.I. 9417135- CANADIAN MUTUAL FUND TRUST-NON-RESIDENT-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 The Canada-Germany Convention does not reduce the 25% withholding tax applicable to distributions by a Canadian mutual fund trust to a resident of Germany. ...

22 August 1995 External T.I. 9520405 - TREATY ("RESIDENCE") STATUS OF A "S" CORPORATION -- summary under Article 4

22 August 1995 External T.I. 9520405- TREATY ("RESIDENCE") STATUS OF A "S" CORPORATION-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Because an S corporation will be subject to tax in the U.S. on its world-wide income if certain conditions are not met, it is considered to be a resident of the U.S. for purposes of the Canada-U.S. Convention. ...

1 February 2002 External T.I. 2001-007820 -- summary under Article 11

1 February 2002 External T.I. 2001-007820-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The exclusion in subparagraph 3(b) of Article XI of the Canada-Argentine Convention is applicable where the payor of the interest is not the final user of the purchased machinery. ...

28 December 2000 External T.I. 2000-0003915 - Article XXVI A of Canada-US Tax Treaty -- summary under Article 26A

28 December 2000 External T.I. 2000-0003915- Article XXVI A of Canada-US Tax Treaty-- summary under Article 26A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26A General discussion of Article XXVI A of the Canada-U.S. Convention. ...

HMRC v. Anson, [2013] EWCA Civ 63, rev'd supra -- summary under Article 24

Anson, [2013] EWCA Civ 63, rev'd supra-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 LLC not transparent The taxpayer, who was resident in the UK, paid US income taxes on his share of the profits of an LLC of which he was a member, and also paid UK income taxes on income remitted to the UK including such share of the LLC's profits. He would have been entitled to relief under Art. 23 of the UK-US Double Tax Convention from UK tax on such profits if the UK tax was "computed by reference to the same profits or income by reference to which the United States tax [was] computed. ...

Anson v. HMRC, [2015] UKSC 44 -- summary under Article 24

HMRC, [2015] UKSC 44-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 UK LLC member had a personal (non-proprietary) entitlement to his share of LLC profits as they arose The taxpayer, who was resident in the UK, paid US income taxes on his share of the profits of an LLC of which he was a member, and also paid UK income taxes on income remitted to the UK including such share of the LLC's profits. He would have been entitled to relief under Art. 23 of the UK-US Double Tax Convention from UK tax on such profits if the UK tax was "computed by reference to the same profits or income by reference to which the United States tax [was] computed. ...

14 May 1991 T.I. (Tax Window, No. 3, p. 10, ¶1237) -- summary under Article 5

(Tax Window, No. 3, p. 10, ¶1237)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. corporation may be considered to be carrying on business in Canada where it supplies to its Canadian subsidiary employees that are under its direct control and supervision, in which case the provision of space to the employees at the Canadian subsidiary may constitute a place of business for purposes of Article V of the Canada-U.S. Convention. ...

8 October 1992 T.I. 920970 (September 1993 Access Letter, p. 419, ¶C111-056) -- summary under Article 13

8 October 1992 T.I. 920970 (September 1993 Access Letter, p. 419, ¶C111-056)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Where a property drops in value after 1984 and then recovers before the date of its disposition, the availability of any transitional relief in paragraph 9 of Article XIII of the Canada-U.S. Convention should be discussed with the competent authority. The acquisition of a depreciable property on a partial (1/2 step-up basis) under former s. 70(5)(b) would be regarded as a non-recognition transaction for the purposes of paragraph 9. ...

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