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Convention. ...

28 March 2012 External T.I. 2011-0395201E5- IT-496R-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) Where IT-496R, para. 12 indicates that payments may be made to delegates to cover expenses of attending conventions and meetings, "delegates" "generally means a person sent or authorized to represent others," so that it is possible that an individual will be a delegate even where the individual has no authority to vote. ...

XII, para. 4(a) of the Canada-France Convention are satisfied. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

9 September 2004 External T.I. 2004-007035-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. ...

27 April 2012 External T.I. 2011-0429361E5- India non-resident activities in Canada-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 marketing in Canada through unrelated corp A corporation resident in India which engages in residential development in India and does not have an office in Canada would likely not have a permanent establishment in Canada by virtue of engaging an unrelated Canadian corporation ("Canco") to advertise in Canada for the sale of Indian condos and provide interested parties with information, with Canco (which does not have authority to conclude contracts) directing parties who are still interested to contact the Indian corporation directly. ...

6 August 2004 External T.I. 2004-0066621E5- Irish Investment Undertakings-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Irish investment undertakings not Treaty residents Three entities (a unit trust, investment company and limited partnership) which were certified by the Irish Revenue Commissioners to be investment undertakings which were resident in Ireland for income tax purposes and thereby subject to Irish tax legislation were found not to be resident under the new Treaty as they were not subject to comprehensive taxation in Ireland (i.e., they currently were not chargeable to Irish tax on their income). ...

2008 Ruling 2008-0272141R3- Conversion of Delaware corporation into LLC-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 disposition of tcp through U.S. holdco was exempted The shares of a U.S. corporation (D Co) holding two Canadian subsidiaries (G Co and H Co) whose shares are taxable Canadian property are contributed by its U.S. ...