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

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 contingent interest under Art. ...

The tax-deferred rollover is not available for amounts which are received on a periodic basis out of the pension plan, nor is it available for amounts for which the recipient has taken a deduction under subparagraph 110(1)(f)(i) due to a specific provision of the Canada-UK Tax Convention. … [but here] no [such] deduction would be available …. ...

26 November 2020 STEP Roundtable Q. 4, 2020-0838001C6- Foreign Tax Credit-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 a capital gain’s geographic source for Canadian FTC purposes was re-sourced to Australia under the Treaty-source rule A Canadian-resident individual (the “Taxpayer”), wholly owns a U.K. ...

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25 November 2021 CTF Roundtable Q. 4, 2021-0912111C6- Liable To Tax & Territorial Taxation-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis- provided its CMC was there Generally, a person must be “liable to tax” in a contracting state to be a resident there for treaty purposes. ...

.-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction Where dividends paid by a resident corporation resident to a resident personal discretionary trust are deemed pursuant to s. 104(19) to be received by a beneficiary that is resident, but not domiciled in Barbados (“NR-Beneficiary”), would those dividends be subject to a reduced rate of withholding at 15% pursuant to Arts. ...

XIII(7) Canada-US Treaty and Trusts-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. ...

17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 whether employee’s home office can constitute a PE of US employer 50 of the 1,000 employees of USco (a US C-Corp and a “qualifying person” for purposes of the Canada-US Treaty) are Canadian residents who are allowed, but not required, to work from home for two or three days a week. ...

14 December 2023 External T.I. 2019-0820291E5- Meaning of "Capital"-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 capital for purposes of determining a Canadian Treaty-reduced dividend withholding rate of 5% references stated capital The 1,000 common shares of Canco (a Canadian-resident corporation), which had an aggregate fair market value (FMV) and stated capital of $1,000 and $100, respectively were owned equally by five shareholders, and an Israeli corporation held 100,000 preferred shares with an FMV and stated capital of $1,000,000 and $100, respectively, which were redeemed in its hands. ...