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2014 Ruling 2014-0527221R3- Disposition of shares under Canada-Israel Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 "consist of" not a "derived from" test Current structure Foreign Parent, an Israeli public company, holds its LP interest in LP through a Canadian subsidiary (Canco1) and holds its GP interest through a Canadian subsidiary (Canco1) of an immediate Israeli subsidiary (Foreign Holdco) of Foreign Parent. ...

2014 Ruling 2014-0534751R3- Deemed dividends from ULC holdco and Art IV(7)(b)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 2-step PUC increase and distribution by ULC coupled with dividend paid directly by exchangeable share sub of ULC to U.S. ...

Convention as well as being effectively managed and controlled there, and does not have a permanent establishment in Canada. ...

20 November 2014 Internal T.I. 2014-0539631I7- Restrictive Covenants-Part XIII (Luxembourg)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 restrictive covenant payment not eligible for relief under Lux Treaty Shares of SubCo held by LuxCo (as a capital investment) and CanCo were sold to a third party. ...

Income Tax Convention was described as an identifiable location with a certain degree of permanence in which the business of the enterprise is being carried on. ...

10 February 2015 External T.I. 2013-0484501E5- Treaties Article XV-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 $10,000 safe harbour for Canadian employment income of U.S. resident applied on calendar year basis even where he was a part-year resident Part-way through a year an individual ceased to be Canadian-resident and became a U.S. resident but derived employment income from the exercise of his employment in Canada with the same employer throughout that year, of which the portion earned while he was non-resident did not exceed Cdn.$10,000. ...

.-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 REIT income distributions to IRA at 15% An IRA account of Mr. ...

2014 Ruling 2014-0521831R3- Withholding on interest payments-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 interest paid within consolidated U.S. group re acquisition of Cdn hybrid LP is Treaty-exempt Structure US Parent Co, which is a U.S. public corporation and a qualifying person under the Canada- U.S. ...

Convention) will incorporate Canco under Part 2 of the Canada Not-for-profit Corporations Act and become the sole member and grant a non-transferable, non-exclusive licence to Canco to market and sublicense Forco's Custom Software to sub-licensees under an Agreement to sell the Custom Software in Canada. ...

23 October 2012 External T.I. 2012-0440101E5- Article X(6) Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 A US LLC, which has two US-resident members (either two corporations or an individual and a corporation) who qualify for Treaty benefits, carries on business in Canada through a permanent establishment. ...