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17 December 2002 External T.I. 2002-0155005 - FTC for U.K. Dividends -- summary under Article 10

Dividends-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Following the repeal of U.K. ... Convention continues to apply since individuals in the United Kingdom are still entitled to a tax credit in respect of dividends paid by a U.K. company. ...

30 November 1999 External T.I. 9826935 - PERMANENT ESTABLISHMENT -- summary under Article 5

30 November 1999 External T.I. 9826935- PERMANENT ESTABLISHMENT-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 In response to an inquiry as to whether a ship of a Norwegian corporation that was outfitted for the purpose of undertaking underwater seismic surveys and that would be operated in Canadian territorial waters under a time charter agreement for approximately three years, RC stated: "In general, a ship will constitute a fixed place of business under the Convention if it is linked to a specific geographical location (i.e., by virtue of being anchored in a particular place) or if the ship operates in a geographically limited area for an extended period of time. ...

6 April 2023 Internal T.I. 2022-0929731I7 - Articles 18(2) and (3) of the Canada-Italy Treaty -- summary under Section 5

6 April 2023 Internal T.I. 2022-0929731I7- Articles 18(2) and (3) of the Canada-Italy Treaty-- summary under Section 5 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 5 CPP and OAS are normally considered pensions for Treaty purposes Regarding the receipt by an individual resident in Italy of periodic Canada Pension Plan (“CPP”) and Old Age Security (“OAS”) benefit payments, the Directorate stated: [S]ection 5 of the Income Tax Conventions Interpretations Act provides a definition of the term “pension” in respect of payments that arise in Canada. ...

Chua v. MNR, 2000 DTC 6527 (FCTD) -- summary under Subsection 15(1)

Convention was contrary to section 15 of the Charter in light of the citizenship preference contained in paragraph 8 of Article XXVI A. ...

Rutenberg v. MNR, 79 DTC 5394, [1979] CTC 459 (FCA) -- summary under Article 3

MNR, 79 DTC 5394, [1979] CTC 459 (FCA)-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 Canadian real estate dealings of the U.S. ...

Padmore v. IRC, [1987] BTC 3 (Ch. D.), aff'd [1989] BTC 231 (C.A.) -- summary under Article 4

.)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 A Jersey partnership comprising over 100 U.K. resident partners and carrying on a trade which was managed and controlled in Jersey, was a body of persons resident in Jersey rather than in the U.K. in the context of the provisions before the English court. ...

Levert v. The Queen, 2001 DTC 781 (TCC) (Informal Procedure) -- summary under Article 18

The Queen, 2001 DTC 781 (TCC) (Informal Procedure)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 A disability pension received by the taxpayer from the United Steelworkers of America as a result of group term life insurance provided by them was exempt from tax under the Act in light of evidence that the payments were exempt under the Internal Revenue Code. ...

Placrefid Ltd. v. MNR, 86 DTC 1327, [1986] 1 CTC 2449 (TCC) -- summary under Article 5

MNR, 86 DTC 1327, [1986] 1 CTC 2449 (TCC)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Canadian counsel of the taxpayer did not constitute a permanent establishment because he could not commit himself on behalf of his client unless specifically authorized by a document to do so. ...

Yoon v. The Queen, 2005 DTC 1109, 2005 TCC 366 -- summary under Article 4

The Queen, 2005 DTC 1109, 2005 TCC 366-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Given the depth of her roots in South Korea, the taxpayer's centre of vital interests was in South Korea rather than Canada. ...

2 August 2012 External T.I. 2011-0422781E5 - Part XIII tax-fee to use on-line trading program -- summary under Article 12

2 August 2012 External T.I. 2011-0422781E5- Part XIII tax-fee to use on-line trading program-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 fee for software use is not generally a royalty unless Treaty so directs The taxpayer inquired about whether Part XIII tax is payable in respect of a "licence fee" paid to a non-resident for access to "an on-line marketplace trading platform" similar to eBay, and in particular whether such fees are royalties. CRA replied that the OECD Model Convention provides that a fee for the use of computer software is not characterized as a royalty for treaty purposes, and stated that such a fee would not be a royalty unless the bilateral tax treaty in issue "includes an intellectual property clause specifically providing that payments for digital property are considered taxable as a royalty. ...

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