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31 May 2013 External T.I. 2013-0486011E5- Loan to non-resident- Part XIII tax-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 partnership fiscally transparent for Treaty withholding purposes re s. 15(2) loan made by it A Canadian-resident corporation (CanCo1) and its wholly-owned Canadian-resident subsidiary (CanCo2) are the 99% limited partner and 1% general partner, respectively, of CanLP. ...

20 July 2015 Internal T.I. 2012-0457671I7- Treaty triangulation- Article 15-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 treaty-exemption for remuneration of NR employee employed in deemed offshore drilling PE of employer resident in 2nd treaty county Mr. ...

22 February 2016 External T.I. 2014-0525681E5- Taxation of inherited pension plan payment-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 exclusion re US estate tax A U.S. citizen is resident in Canada and was the beneficiary of a deceased U.S resident who had been a retired member of a U.S. public pension plan. ...

26 May 2016 IFA Roundtable Q. 9, 2016-0642131C6- Article IV(7) and S-Corporations-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 US-Treaty benefits denied on interest paid by a transparent ULC sub to an S-Corp US Parent, which has elected to be treated as an “S-corporation,” so that it is fiscally transparent for Code purposes and its shareholders are taxable in respect of its income, owns all the shares of US Sub, which has elected to be treated as a “Qualified Subchapter S Subsidiary” and also is fiscally transparent for Code purposes. ...

16 January 2017 External T.I. 2016-0655701E5- Article 5(3)- Demolition-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 decommissioning work is of the type covered by the construction PE Article/aggregation of subcontracts to exceed 12 months A Canadian resident company (“Customer”), which is awarded a decommissioning contract for a number of offshore oil/gas platforms (the “Main Contract”), subcontracts some of the required work to an affiliate (“Non-Resident”), which is resident in a country whose treaty uses Art. 5(3) of the OECD model. ...

8 September 2017 External T.I. 2014-0549771E5- Article XXIX-A:3-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A a trust is related for purposes of Art. ...

22 September 2017 External T.I. 2016-0668041E5- TCP and Article 13(5) of Canada-UK Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 proportionate value approach to determining whether shares of a foreign holding company are derived more than 50% from Canadian immovable property for Treaty purposes A Netherlands corporation (BVCo) holds 1/3 of its assets as shares of an Australian subsidiary (“AusCo”), whose Australian real estate assets represent 5/6 of the consolidated assets, but also with high liabilities, and holds 2/3 of its assets as shares of a Canadian subsidiary (“TCPCo”) whose Canadian real estate assets represent 1/6 of the consolidated assets, but with low leverage. ...

28 March 2018 External T.I. 2016-0672941E5- Par. 2 of Norway Other Income treaty Article-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 a tax-exempt Norwegian fund received a Canadian REIT distribution that was “taxable” in Norway, so that Treaty-reduced withholding applied An entity (the “Tax Exempt Entity”) that is a resident of Norway per Art. 4(1) of the Treaty and that is exempt from income tax liability under Norway income tax law, maintains an investment fund (the “Fund”) whose assets are held by it directly but segregated from its other assets. ...

27 March 2018 External T.I. 2017-0715561E5- Withholding tax on royalties for streamed content-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 television and broadcasting included digital streaming Canco streams movies and TV shows (the “digital content”) to its Canadian and foreign subscribers (who pay monthly fees) through a TV video stream and a digital content library. ...

27 January 2003 External T.I. 2002-0169385 F- Un serveur et l'établissement stable-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Canadian servers of Swiss company would not be a PE if sales of its product not made through the website A Swiss corporation engaged in various countries in selling products and that uses a Canadian subsidiary to promote the products will use Canadian servers for its website, which will provide information on the corporate group in general and will incidentally include information on the Canadian subsidiary. ...