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6 July 2012 Internal T.I. 2012-0440741I7 - stock option benefit derived by US resident -- summary under Article 15

6 July 2012 Internal T.I. 2012-0440741I7- stock option benefit derived by US resident-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 U.S. subs qualifies as payer of (therefore exempt) stock option benefit/domestic v. Treaty method USCo, which is a qualifying person for purposes of the Canada-US Income Tax Convention and is a wholly-owned subsidiary of a Canadian public company, employed a US-resident individual who performed employment duties for USCo in Canada for 55, 100 and 75 days in 2009, 2010 and 2011, respectively. ... Before considering the effect of the exemption in para. 2 of Article XV of the Canada-US Convention, CRA noted that under the methodology in Annex B to the Fifth Protocol, the stock benefit realized in 2010 would be apportioned to Canada based on the relative number of working days in Canada over the two-year period between the grant and exercise of the options. ...

MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct) -- summary under Subsection 212(5)

Income Tax Convention. ...

Qing Gang K. Li v. The Queen, 94 DTC 6059, [1994] 1 CTC 28 (FCA) -- summary under Article 20

The Queen, 94 DTC 6059, [1994] 1 CTC 28 (FCA)-- summary under Article 20 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 20 The taxpayer, a Chinese citizen, entered Canada on a visitor's visa in 1984, and in 1987 married a Canadian citizen and applied for landed immigrant status. ...

Black v. The Queen, 2014 DTC 1046 [at at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275 -- summary under Other/Conflicting Statutes

The Queen, 2014 DTC 1046 [at at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275-- summary under Other/Conflicting Statutes Summary Under Tax Topics- Statutory Interpretation- Other/Conflicting Statutes presumption against inconsistency Before finding that there was no inconsistency in the taxpayer being resident in Canada for purposes of the Act and a resident of the U.K. for purposes of the Canada-U.K Income Tax Convention,, Rip CJ stated (at para. 67): In Friends of the Oldman River Society v. ...

Sutcliffe v. The Queen, 2006 DTC 2076, 2005 TCC 812 -- summary under Article 15

The Queen, 2006 DTC 2076, 2005 TCC 812-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 The taxpayer was a U.S. resident who was employed by Air Canada as a pilot on domestic flights (between Toronto and other Canadian cities) and international flights (between Toronto and U.S. cities). ...

Gulfmark offshore N.S. Limited v. Canada, 2007 DTC 5563, 2007 FCA 302 -- summary under Article 7

Canada, 2007 DTC 5563, 2007 FCA 302-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Before the taxation year in question, the taxpayer, which was a U.K. company with a fleet of 27 supply vessels including a ship that was operated for 88 days in that year in the Nova Scotia offshore area, borrowed money from its parent company to construct new ships in addition to the refinancing of the taxpayer's outstanding debts. ...

Donroy, Ltd. v. U.S., 301 F. 2d 200 (9th. Cir. 1962) -- summary under Article 5

Cir. 1962)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Canadian corporations, which were limited partners of a California limited partnership with a U.S. general partner and a business office in San Francisco, were found to have a permanent establishment in the U.S., in light of the Court's recognition (at p. 208): "that the general partners are the general agents of the limited partners for the general purpose of conducting the business- subject only to the statutory exemption of limited partners from direct obligation to creditors beyond their stated financial commitment- and that all the partners have an interest in the partnership assets, including its office. ...

Imray v. The Queen, 98 DTC 6580, 1998 CanLII 8609 (FC), [1998] 4 CTC 221 (FCTD) -- summary under Paragraph 8(1)(h)

In finding that the taxpayer's related traveling expenses were deductible, Campbell J. stated (at p. 6585) that he had "no hesitation in finding that teachers' convention attendance is 'normal', 'a matter of regular occurrence', 'commonly' and 'usually' occurs, and is a requirement which takes teachers 'from time to time away from the places which they usually work'. ...

Boston v. R., 98 DTC 1124, [1998] 1 CTC 2217 (TCC) -- summary under Article 4

., 98 DTC 1124, [1998] 1 CTC 2217 (TCC)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The taxpayer was posted to Malaysia, where he lived in rented premises. ...

R. v. Melford Developments Inc., 82 DTC 6281, [1982] CTC 330, [1982] 2 SCR 504 -- summary under Subsection 214(15)

However, in the absence of the overriding effect of any Convention, the effect of s. 214(15) is to convert guarantee fees into "interest" for the purpose of the withholding tax provisions of that Part. ...

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