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Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation, [2024] FCAFC 29 -- summary under Article 9

Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation, [2024] FCAFC 29-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 an independent enterprise would have agreed to allow interest to be capitalized, but not to make it contingent on cash flow The taxpayer (“STAI”)- a wholly-owned Australian subsidiary of a Singapore public company (Singapore Telecommunications Limited, or “SingTel”)- purchased in June 2002 all the shares of an Australian telecommunications company (“SOPL”) from another wholly-owned subsidiary of SingTel (“SAI”), which was accepted to be a Singapore enterprise. ...

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152 -- summary under Article 12

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose BLM was a substantial Irish-resident investment company, which started acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) in 2011 and came to own 443 such claims. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2 -- summary under Article 6

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty is not income from immovable property under the Canada-U.K. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2 -- summary under Article 6

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty was too remote from a land interest in the oil field to be immovable property under the Canada-U.K. ...

9 April 2013 External T.I. 2012-0461051E5 F - Employee of an international organization -- summary under Paragraph 81(1)(a)

The XXXXXXXXXX Order was issued pursuant to paragraph 5(1)(g) of the FMIOA and provides that XXXXXXXXXX officials have in Canada the privileges and immunities set out in Article V of the UN Convention. ...

2013 Ruling 2012-0444431R3 - Taxable Canadian Property -- summary under Article 13

2013 Ruling 2012-0444431R3- Taxable Canadian Property-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 NR partnership holding real property interests through debt A partnership (Foreign Partnership), whose non-resident members (Investors) are resident in Foreign Countries 1 through 5, uses a portion of its cash from unit and loan subscriptions to subscribe for equity of a Newco resident in Foreign Country 6 (Foreign Parent), and applies the balance of its subscription cash to subscribe for a mixture of profit-participating loans and non-interest-bearing loans of Foreign Parent (the Foreign Parent Loans). ...

12 February 2014 External T.I. 2013-0486931E5 - Distribution by ULC to a Trust to a NR beneficiary -- summary under Article 4

12 February 2014 External T.I. 2013-0486931E5- Distribution by ULC to a Trust to a NR beneficiary-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 hybrid trust holding ULC Trust is resident in Canada, is not subject to s.75(2), has one individual beneficiary (the "Non-resident Beneficiary") who is a a qualifying person for the purposes of the Canada-U.S.Treaty, and is the sole-shareholder of a Canadian-resident unlimited liability company. ...

2014 Ruling 2013-0491331R3 - Introduction of a partnership and Art.IV(7)(b) -- summary under Article 4

2014 Ruling 2013-0491331R3- Introduction of a partnership and Art.IV(7)(b)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Art. ...

2012 Ruling 2011-0403291R3 - Treaty exempt sale -- summary under Article 13

2012 Ruling 2011-0403291R3- Treaty exempt sale-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Treaty step-up to avoid the application of s. 55(2) to a spin-off made to effect an arm's length sale of the rump Following a preliminary reorganization (including an amalgamation of predecessors of Amalco so as to "consolidate the tax attributes"), all the shares of Amalco are held by Foreignco3 (resident in the U.S.) which, in turn, is an indirect wholly-owned subsidiary of Foreign Parent, a listed company. ...

26 August 2013 Internal T.I. 2013-0494211I7 - participating debt interest -- summary under Article 11

26 August 2013 Internal T.I. 2013-0494211I7- participating debt interest-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Cdn petroleum exploration company with no extracted petroleum pays participating interest re price of petroleum Canco, which carries on a business of exploring and developing oil and gas properties in Canada (so that its principal assets consist of rights to explore for and exploit oil and gas), and which does not own any inventory of oil or gas, pays interest to a resident of the US (which is a "qualifying person" within the meaning of Art. ...

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