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21 October 2021 Internal T.I. 2020-0872281I7 - S.219 and Article X(6) of the Canada-US Treaty -- summary under Article 10

21 October 2021 Internal T.I. 2020-0872281I7- S.219 and Article X(6) of the Canada-US Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 different treatment of losses under Pt. ...

23 November 2023 Internal T.I. 2020-0850381I7 - Article V(4) of the Canada-U.S. Treaty -- summary under Article 5

Treaty-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time Art. ...

2024 Ruling 2023-0984281R3 - Remote services and permanent establishment -- summary under Article 5

2024 Ruling 2023-0984281R3- Remote services and permanent establishment-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ruling that using employees to provide on-line health services to non-resident patients from home offices in Canada does not create a PE in Canada Background The three taxpayers (the “Taxpayers”), which are corporations resident in Countries A, B and C for purposes of Canada’s treaties with those countries, and which have never filed Canadian returns, use employees residing in those respective countries to provide online (e.g., by phone or video) services (“Services”) to patients (“Clients”) in the same time zone. ...

4 June 2024 STEP Roundtable Q. 11, 2024-1003491C6 - Foreign Tax Credit for US Estate Tax -- summary under Article 29B

4 June 2024 STEP Roundtable Q. 11, 2024-1003491C6- Foreign Tax Credit for US Estate Tax-- summary under Article 29B Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29B application of Art XXIX-B(6)(a) of the Canada-US treaty where s. 70(5) gain realized on US public company shares and US realty A Canadian resident who was not a U.S. citizen was subject on death to U.S. estate tax on U.S. situs property, namely, US real property and shares of a U.S. public corporation that were not “U.S. real property interests” – and also realized a gain pursuant to ITA s. 70(5). ...

Lee A. Sheppard, "The Brave New World of the Dependent Agent PE", Tax Notes International, Vol. 71, No. 1, 1 July 2013, p. 10 -- summary under Article 5

Sheppard, "The Brave New World of the Dependent Agent PE", Tax Notes International, Vol. 71, No. 1, 1 July 2013, p. 10-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A June 14, 2013 conference sponsored by the Vienna University of Economics and Business discussed the dependent agent permanent establishment concept in Article 5(5) of the OECD Model treaty, which provides: Notwithstanding the provisions of paragraphs 1 and 2, where a person — other than an agent of an independent status to whom paragraph 6 applies — is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. ... Independent agent article of OECD Model Convention (pp. 15-16) Article 5(6) states: An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. ...

2013 Ruling 2012-0467721R3 - IV(7)(b) & PUC increase -- summary under Article 4

2013 Ruling 2012-0467721R3- IV(7)(b) & PUC increase-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 two-step distribution to two S-Corp shareholders of ULC/interest payment to one USCo and USCo2 are each S Corporations whose shares are owned in the same proportions by U.S. ...

15 June 2015 External T.I. 2014-0525501E5 - Royalty payments & the US or UK Treaties -- summary under Article 12

15 June 2015 External T.I. 2014-0525501E5- Royalty payments & the US or UK Treaties-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 fees paid to the U.S. or U.K. for access to customer lists were exempt royalties Canadian-resident UserCos, who use existing confidential lists of the names and addresses of customers who have purchased certain types of products (“Lists”) for marketing purposes, pay CanCo fees based upon their use of the Lists. ...

14 December 2015 Internal T.I. 2014-0558661I7 - Application of Article V(9) to a partnership -- summary under Article 5

14 December 2015 Internal T.I. 2014-0558661I7- Application of Article V(9) to a partnership-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 services PE of U.S. partnership based on collective Canadian activities of all partners Mr. ...

7 September 2016 External T.I. 2014-0563781E5 - Articles 10 and 11 of Canada-UK Treaty -- summary under Article 11

7 September 2016 External T.I. 2014-0563781E5- Articles 10 and 11 of Canada-UK Treaty-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 limited partners of an LP can deal at arm’s length with a Canadian subsidiary of the LP A UK corporation (“GP Co”) is the general partner (with a 1% interest) of a UK limited partnership which is fiscally transparent for UK purposes and a partnership for ITA purposes (“UK LP” – all of whose partners are non-residents), and the Limited Partners include LP1 and LP3, which provide benefits under a “recognized pension plan” (as defined in Art. 10, para. 4 of the Canada-UK Treaty) and own 7% and 11% partnership interests, and LP2, a UK corporation owning a 19% partnership interest. ...

7 September 2016 External T.I. 2014-0563781E5 - Articles 10 and 11 of Canada-UK Treaty -- summary under Article 10

7 September 2016 External T.I. 2014-0563781E5- Articles 10 and 11 of Canada-UK Treaty-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 limited partners generally do not have control over a company’s voting power/an over-10% limited partner is considered to “indirectly” own over 10% of an LP subsidiary A UK corporation (“GP Co”) is the general partner (with a 1% interest) of a UK limited partnership which is fiscally transparent for UK purposes and a partnership for ITA purposes (“UK LP” – all of whose partners are non-residents), and the Limited Partners include LP1 and LP3, which provide benefits under a “recognized pension plan” (as defined in Art. 10, para. 4 of the Canada-UK Treaty) and own 7% and 11% partnership interests, and LP2, a UK corporation owning a 19% partnership interest. ...

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