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17 October 2012 External T.I. 2012-0438671E5- Treatment of German social security pension-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Discussion of treatment of German social security pensions including link to discussion at www.cra-arc.gc.ca/tx/nnrsdnts/ntcs/grmny2005-eng.html. ...

5 October 2012 Roundtable, 2012-0451251C6 F- Excess of foreign tax withheld at source-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax foreign withholdings on American depositary receipts in excess of Treaty-limited rate does not qualify as an income tax Tax is systematically withheld on income from ADRs at above the maximum rates permitted by the conventions. ...

20 November 2014 Internal T.I. 2014-0539631I7- Restrictive Covenants-Part XIII (Luxembourg)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 restrictive covenant payment not eligible for relief under Lux Treaty After CanCo had sold shares of a partly-owned subsidiary (SubCo), it made a payment to the other share vendor (LuxCo) pursuant to what was assumed to be a "restrictive covenant" in a related agreement, and withheld and remitted 25% of the payment. ...

XV of Canada-France Convention, as not being in respect of employment exercised in Canada, or Art. ...

23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 non-application of Art. 12 of US Treaty to resource royalties Mr. ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...

28 November 2011 CTF Roundtable, 2011-0425901C6- Does share derive value principally from real prop-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 whether shares derive their value from real property is determined irrespective of debt allocation After the questioner referenced the previous position that, in the context of Treaty references to shares deriving in their value principally from real property, CRA would accept a valuation method that assigned the debt of a company to the assets to which the debt reasonably related, CRA stated: In the context of tax treaties...the determination whether a share of a company derives its value principally from real or immovable property situated in Canada should be made by reference to the value of the properties of the company without taking into account its debts or other liabilities. ...

16 June 2014 Internal T.I. 2014-0527901I7- Public Lending Right Payments under Art. 14-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 public lending right payments not royalties Payments made by the Canada Council under the public lending rights program, i.e., payments to Canadian authors in order to compensate them for the free access to their works in Canadian libraries "would be in respect of their independent literary or artistic activities" rather than (royalty) "payments… made in consideration for the use of, or the right to use, the work being lent out (or their copyright in the work)," so that in the case of a resident of Ireland receiving a PLRP payment, that payment would be taxable in Canada only to the extent that the author has a fixed base in Canada for the purposes of performing their "professional services" and only to the extent the PLRP can be attributed to that fixed base. ...

.-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 SIFT distributions respected as dividends An IRA account of Mr. ...

18 June 2013 Internal T.I. 2011-0393451I7- Treaty Exemption- Fixed Base available in Canada-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 A non-resident of Canada who was resident in Ireland for purposes of the Canada-Ireland Treaty, worked as an independent contractor, under a short-term contract for service, for a provincial authority at facilities maintained and operated by it. ...