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Garcia v. The Queen, 2007 DTC 1593, 2007 TCC 548 (Informal Procedure) -- summary under Article 4

The Queen, 2007 DTC 1593, 2007 TCC 548 (Informal Procedure)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The taxpayer, who was resident both in Canada and the United States in 2003 when he received a bonus that had been earned in 2002, was found to be resident for Treaty purposes in Canada given that he owned a home in Canada and did not own, rent or occupy any home, permanent or otherwise, in the U.S. ...

SPG International Ltée v. R., [1998] 3 CTC 2046, 98 DTC 1706 (TCC) -- summary under Financing Expenditures

Various expenses paid by the taxpayer including trade convention reservation fees, and travelling expenses incurred by the subsidiary's general manager, which were booked as advances by the taxpayer to the subsidiary, nonetheless were found to be currently deductible by the taxpayer since they were made for the purpose of promoting the sales of its products. ...

DIT v. FC Bamford Excavators Ltd., ITA No. 540/Del/2011 (14 March 2014 ITAT Delhi) -- summary under Article 5

., ITA No. 540/Del/2011 (14 March 2014 ITAT Delhi)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 seconded employees The taxpayer, a UK company licensed technology to its wholly owned subsidiary, JCB India Ltd, and also seconded eight employees to JCB India. ...

3 October 2014 External T.I. 2013-0509751E5 - RRSP or RRIF payments to a resident of New Zealand -- summary under Article 18

3 October 2014 External T.I. 2013-0509751E5- RRSP or RRIF payments to a resident of New Zealand-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 meaning of periodic pension payment in NZ Treaty How is the tax treatment of RRSP payments (either periodic or in a lump-sum) or RRIF payments made to non-residents in New Zealand affected by the new Canada-New Zealand Treaty? CRA stated: It should be noted that under the definition of "periodic pension payment" in section 5 of the [Income Tax Conventions Interpretation Act], neither a payment from an RRSP before maturity or in full or partial commutation of the retirement income under an RRSP (such as a a fixed or single lump-sum payment from your RRSP annuity that is equal to the current value of all or part of your future annuity payments from the plan), or a payment from a RRIF that exceeds either twice the minimum payment or the 10% threshold, is considered to be a "periodic pension payment". ...

28 November 2010 CTF Roundtable Q. 9, 2010-0387091C6 - Late filing of T1 returns -- summary under Article 5

28 November 2010 CTF Roundtable Q. 9, 2010-0387091C6- Late filing of T1 returns-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Suppose a US-resident taxpayer provides services in Canada for 130 days between 1 October to 28 February, does not anticipate providing further services in Canada, and obtains regulation 105 waivers for services provided in that period. ... V(9)(a) of the Canada-US Convention retroactively to impute a permanent establishment. ...

23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under Article 6

23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 negative CCDE gain from grant of oil and gas royalty not exempt under US Treaty Mr. ... Treaty and in the Income Tax Conventions Interpretation Act, and stated: Therefore, if Mr. ...

29 August 1995 External T.I. 9506785 - PROPERTY...IN WHICH BUSINESS OF CO CARRIED ON -- summary under Article 13

29 August 1995 External T.I. 9506785- PROPERTY...IN WHICH BUSINESS OF CO CARRIED ON-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 exclusion from immovable property for property in which business is carried on requires active and regular involvement "Property... in which Business of Co. Carried on"): Respecting the exclusion in Article XIII, paragraph 4 of the Canada-Netherlands Convention for property (other than rental property) in which the business of the company is carried on, RC stated that in its view "Oil & Gas reserves and royalty interests will be excluded from the definition of immovable property... if the owner is actively engaged in the exploitation of natural resources and if such assets are actively exploited or kept for future exploitation by such owner.... ...

12 September 2019 External T.I. 2017-0732681E5 - Payment of pension surplus to US resident beneficiary -- summary under Periodic Pension Payment

12 September 2019 External T.I. 2017-0732681E5- Payment of pension surplus to US resident beneficiary-- summary under Periodic Pension Payment Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 5- Periodic Pension Payment winding-up IPP payment or commutation or minimum amount payments are not periodic The U.S. ... CRA rejected the taxpayer submission that the IPP winding-up distribution was “simply an extension of the periodic guarantee payments,” and found that, since it was a lump sum payment as referenced in the definition of “periodic pension payment” in s. 5 of the Income Tax Conventions Interpretation Act, it was subject to withholding at 25%. ...

Fowler v HM Revenue and Customs, [2018] EWCA Civ 2544, rev'd 2020 UKSC 22 -- summary under Article 3

Fowler v HM Revenue and Customs, [2018] EWCA Civ 2544, rev'd 2020 UKSC 22-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 a domestic provision deeming employment income to be from trade rendered it business profits for Treaty purposes The taxpayer was a resident of South Africa for purposes of the U.K-South Africa Convention (the “Treaty”) who, as an employee, undertook diving engagements in the UK continental shelf waters. ...

Wolf v. Canada, 2019 FCA 283 -- summary under Article 5

Canada, 2019 FCA 283-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 quaere whether individual could derive business revenues through his enterprise through an LLC A U.S. engineer provided services to Bombardier in Canada over a 188-day period (straddling the 2011 and 2012 years). ... Therefore, the gross revenue test as set out in subparagraph 9(a) of Article V of the Tax Convention would be satisfied. ...

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