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8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A The correspondent noted that in Canada, if each class of shares of a public company with multiple classes must be considered separately for purposes of satisfying the de minimis or 10-percent tests in the U.S. tax regulations (treated as being applicable for Canadian purposes under para. 2(c) of the "qualifying person definition) very few Canadian corporations with multiple classes of voting shares will be considered "qualifying persons" for purposes of the LOB clause. ...

XIII, para. 8 of the Canada-UK Convention on the basis of an internal estimate prepared by Canco management that the going concern value of the gas storage business carried on by Canco (which was carried on in real estate facilities held on leased land) was greater than X% of the value of the shares of Canco, and that the hydrocarbon assets of Canco did not exceed Y% of the assets of Canco. ...

2010 Ruling 2010-0364531R3- Deemed dividends derived by US Residents-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 PUC increase and distribution by ULC owned by S corp and US LP Canco1, which is an Canadian unlimited liability company that is owned, in part, by S corps and by a US limited partnership whose partners are US-resident individuals and trusts and that has elected to be taxed as a partnership for US tax purposes, increases the capital account of its shares through a transfer from retained earnings and then makes a cash distribution to each shareholder as a return of capital. ...

17 July 2008 IFA Roundtable, 2008-0272361C6- Limitation of Benefits-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A look-through of fiscally transparent entities for qualified person purposes Will CRA look through LLCs and other entities that are fiscally transparent for US purposes, in applying paras. 2(d) and (e) of "qualifying person" of Art. ...

2010 Ruling 2010-0361591R3- Article IV(7)(b) Restructuring-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Art. ...

2007 Ruling 2006-0211991R3- Part XIII Tax-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 bareboat charter not giving rise to PE in Canada Transactions Foreign Co, a Norwegian limited liability company, entered into the Agreement for the bareboat charter to it of the Ship from a Norwegian partnership (Partnership IX), and entered into the Contract for the time charter of the Ship to Canadian resident companies (the “Cancos”) for use of the Ship in relation to a facilities located in Canada and owned by the Cancos. ...

Where the individual's services are exclusively performed in Canada, the entire benefit will be sourced to Canada based on the allocation method set out in Annex B to the 5th Protocol to the Canada-US Convention. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. 24(5) of US treaty a complete code for US citizens A U.S. citizen is required to pay U.S. tax on dividends and capital gains at a 20% rate (increased from the previous 15% rate). ...

16 June 2014 Internal T.I. 2014-0525961I7- ON Tax and Brazilian Tax Sparing-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Brazilian tax-sparing rules operate independently of s. 126 Was tax deemed to have been paid (a "tax spared amounts") under Art. 22, para. 3 of the Canada-Brazil Treaty eligible for a foreign tax credit (an "ON FTC") under s. 34(1) of the Taxation Act, 2007 (Ontario) ("the TA")? ...

CTF 2012- Q.10 US LLC-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 LLC not entitled to Treaty benefits except under IV.6 As CRA is not in agreement with the decision in TD Securities (which, in any event, involved pre-5th Protocol timeframes). ...