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18 June 2013 Internal T.I. 2011-0393451I7- Treaty Exemption- Fixed Base available in Canada-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Dudney folowed 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. ...

21 October 2013 External T.I. 2013-0477121E5- FTC and US Expat Regime-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 FTC for 30% US pension withholding A taxpayer who has renounced his US citizenship elects under Code s. 877A to irrevocably waive any right to claim any reduction in withholding on future pension payments under any US treaty and pay a flat 30% US tax on the taxable portion of all future pension payments. ...

XII, para. 4 of the Canada-US Tax Convention would be exempt from Part XIII tax as being for the use of information concerning industrial or commercial experience. ...

22 May 2014 May IFA Roundtable, 2014-0526711C6- Article XXIX-A(3) of the US Treaty-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A tcp gains on U.S. shares derived from Canada under para. 3 UK Parent owns US Parent, which owns US Holdco (whose shares are taxable Canadian property) which owns Can Sub. ...

2014 Ruling 2013-0511761R3- Cross-border financing Canada- USA-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A interest paid to U.S. sister of LLCs carrying on same business eligible under para. 3 ForSub, which is a U.S. ...

17 May 2012 IFA Roundtable, 2012-0444041C6- IFA 2012- Beneficial Ownership-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 beneficial owner must have discretion for use When asked to "comment on what factors it will take into account in determining beneficial ownership," CRA stated: Where a recipient of income does not receive the payment as agent or nominee for another party, the CRA will consider the recipient to be the beneficial owner of the income if the payment is received for the recipient's own use and enjoyment and the recipient assumes risk and control over the payment. ...

22 March 2016 Internal T.I. 2016-0632941I7- BEPS exchange of tax rulings-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 types of rulings exchanged under BEPS In the context of Canada’s BEPS commitment to exchange information with other countries on certain tax rulings, effective April 1, 2016 IC 70-6 will be revised to indicate that summaries of the contents of the following categories of rulings may be exchanged with the countries of residence of the immediate and ultimate parent and certain other parties (which countries may then ask to receive relevant portions in more detail)- re: a) preferential regimes (for Canada, including international shipping and certain foreign life insurance operations of a Canadian company); b) cross-border transfer pricing; c) downward adjustment not directly reflected in the taxpayers’ accounts; d) permanent establishments; and e) related party conduits. ...

7 September 2016 External T.I. 2014-0559751E5- Subsection 115(3)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 comparison of Treaty and domestic method for pilot income on annual basis S. 115(3) allocates 100%, 50% or 0% of the employment income of a non-resident pilot from a flight to Canada based on whether both, one out of two, or none of the touchpoints were in Canada. ...

17 February 2017 External T.I. 2015-0602781E5- Disposition of farm property by a non-resident-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 shares of Cdn farm are excluded from immovable property under Canada-Germany Treaty A resident of Germany will gift her shares, each qualifying as a “share of the capital stock of a family farm or fishing corporation” under s. 70(10), to her Canadian-resident son who, along with his father, will be actively engaged, on a regular and continuous basis, in carrying on the corporation’s grain farming business in Canada. ...

13 June 2017 STEP Roundtable Q. 9, 2017-0697901C6- S-corporation agreements-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Cdn competent authority agreement with S-Corp. extends to income of a qualified subchapter S Corp. subsidiary thereof Where a U.S. ...