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Convention rather than Article XIV, it is RC's administrative practice to permit fees paid to a non-resident director for services rendered in Canada to be withheld at the flat rate of 15% specified in Regulation 105. ...

Convention rather than Article XIV, it is RC's administrative practice to permit fees paid to a non-resident director for services rendered in Canada to be withheld at the flat rate of 15% specified in Regulation 105. ...

13 July 2009 External T.I. 2009-0318701E5- Article X(2) and Tiered Partnerships-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Where a US corporation that is a qualifying person is a 99.99% limited partner of a Delaware limited partnership which, in turn, is a 99.99% limited partner of a second Delaware limited partnership which owns all the shares of Canco, the US corporation will be considered to have an "ownership interest" in Canco, so that it will be entitled to the 5% rate on dividends paid by Canco. ...

(Tax Window, No. 1, p. 18, ¶1169)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Where a tax-exempt organization is a member of a partnership which has been subject to Part XIII tax on income payments received by it, RC on application of the exempt partner will refund the difference between the pro rata share of the Part XIII tax and the amount which would have been withheld if the exempt partner had received the income directly. ...

(Tax Window, No. 12, p. 17, ¶1559)-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 Where a taxable Canadian corporation leases a ship on a bare boat basis from a corporation resident and managed in the Netherlands, Part XIII tax will be payable on any lease payments relating to voyages made principally for the purpose of transporting passengers or goods between Canadian ports; and the lease payments for other voyages will be exempt. ...

14 November 2007 External T.I. 2007-0253321E5- Non-resident withholding tax-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Respecting whether franchise fees paid to a U.S. resident were subject to withholding tax, the Directorate stated that: "Where a payment represents in part a royalty and in part business profits for purposes of the Treaty, a taxpayer must make reasonable efforts to separate the two. ...

5 January 1993 T.I. 922053 (November 1993 Access Letter, p. 509, ¶C180-153; Tax Window, No. 28, p. 8, ¶2404)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Where a Canadian firm agrees with an American firm to duplicate video cassettes for sale or distribution through rental establishments for non-commercial use by the end users, the payments made for such duplication rights will not be subject to Part XIII tax, even though the source of the work might be a motion picture film. ...

3 August 2004 External T.I. 2003-005125-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Irish UCITS A corporation registered as an Undertaking for collective investment in transferable securities in Ireland would not be eligible as a resident of Ireland for purposes of the new Canada-Ireland Treaty signed on October 8, 2003 as it would not be subject to tax in Ireland. ...

11 October 2013 Roundtable, 2013-0492821C6 F- Question 3- APFF Round Table-- summary under Section 4.3 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 4.3 s. 4.3 precludes application of tie-breaker rule After noting the introduction of s. 4.3, CRA stated: [T]he effect of this new provision is to make it impossible to break the tie [under the Canada-U.S. ...

25 July 2012 External T.I. 2011-0427221E5- FBAR penalties-- summary under Article 26A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26A FBAR penalties not taxes Penalties that the US collects for failure to report Foreign Bank and Financial Accounts information under form TD F90-22.1 ("FBAR penalties") are not a "revenue claim," and CRA will therefore not assist in collecting such penalties. ...