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24 February 2003 Internal T.I. 2002-0165537 F- Le détachement d'employés et l'article XV-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 exemption in Art. 15 of US Treaty unavailable where Canadian employee seconded to US affiliate, which reimburses for his payroll A Canadian resident was seconded to a U.S. corporation related to his Canadian employer in 2001 for a period of less than 183 days, with the U.S. corporation assuming full responsibility for the Canadian resident's employment regarding the employee’s duties in the U.S. ...

If this occurs, since at least one of the partners of LP is a Canadian resident and the interest is paid to a U.S. person, Part XIII tax is exigible, unless such payment is exempt from Canadian taxation under a provision of the Act (such as subparagraph 212(1)(b)(vii)) or the Convention. ...

4 April 2019 Internal T.I. 2017-0736531I7- Articles IV(6) and X(6) of the Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Art. ...

15 May 2019 IFA Roundtable Q. 2, 2019-0798751C6- Shared workspaces and PE-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 a Canadian shared-work space can readily constitute a PE In the following examples, will a U.S. resident carrying on business in Canada, be considered to be a permanent establishment (“PE”) in Canada, assuming Arts. ...

15 May 2019 IFA Roundtable Q. 8, 2019-0798841C6- Active Trade or Business Test under the LOB Clause-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Art. ...

18 April 2019 Internal T.I. 2018-0753621I7- Subsection 247(12)-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 secondary adjustment benefit to a NR sister was a dividend for Treaty purposes Parentco, a U.S. ...

3 December 2019 CTF Roundtable Q. 2, 2019-0824381C6- Foreign taxes paid-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 US and UK Treaties do not eliminate FTC requirement that the taxes be paid Art. ...

18 July 2018 Internal T.I. 2018-0766441I7- Article XXIX(5) and 91(5)-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 agreement with CASD terminated when S Corp. ceased to be fiscally transparent A Canadian resident (and US citizen) had an agreement with the Canadian Competent Authority under Art. ...

2020 Ruling 2019-0801011R3- Article 13(4) of the Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 a Treaty exempted the gain on the sale of a non-resident holding company holding Canadian vacant land Background Mr. ...

15 September 2020 IFA Roundtable Q. 4, 2020-0853391C6- IFA 2020 Q4: Impact Covid-19 on CRA procedures-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 COVID-19 has not changed Treaty time limitations Respecting the pandemic effect on various CRA international programs, CRA indicated: APA and MAP program operations have gradually resumed, and CRA is in contact with its treaty partners using virtual tools such as teleconferencing and, where possible, video-conferencing. ...