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CRA rules that distributions made by a cross-border mutual fund trust to U.S. residents are exempt from withholding

Convention, which applies to income paid by a resident Canadian trust to a resident of the U.S. to the extent such income is "distributed out of income arising outside [Canada]. ...

Dependent agent PE – Das ist klar, nicht wahr?

Email this Content Lee Sheppard has summarized some interesting discussions at a June 2013 conference in Vienna on the dependent agent branch of the permanent establishment definition (Art. 5(5) of the OECD model convention). ...

CRA indicates that vacation days of a contract employee in the US can cause his Canadian employer to have a US permanent establishment

V.9(a) of the Canada-US Convention deems a "Canco," which derives more than 50% of its gross active business revenue from services provided by an employee to US businesses during any 12-month period in which that individual is present in the US for more than 183 days, to be deriving those services through a US permanent establishment (so that the resulting profits are not exempt from US income taxation)- or vice versa in the case of a "USCo" providing services to Canadian businesses through an employee who is present in Canada for more that 183 days in a 12-month period. ...

CRA finds that a Canadian equipment installation project which exceeded 12 months, including on-site preparation of plans and final testing, was a permanent establishment

15 May 2014- 3:37pm CRA finds that a Canadian equipment installation project which exceeded 12 months, including on-site preparation of plans and final testing, was a permanent establishment Email this Content CRA found that a contract of a French company to install specialized equipment at a Canadian factory of an arm’s length Canadian company gave rise to a Canadian permanent establishment of it given its general on-site responsibility for ensuring a successful project and given that the the project lasted more than 12 months including preparing detailed specs on-site and final testing – so that the 12 month safe harbour for installation projects in Art. 5, para. 3 of the Canada-France Convention was not available. ...

CRA indicates that the Treaty does not fetter the right of the US to impose GILTI tax with reference to Canadian subs’ income

Summary of 16 May 2018 IFA Roundtable, Q.1 under Treaties – Income Tax Conventions- Art. 29. ...

CRA indicates that a Canadian shared-work space can readily constitute a PE

Summary of 15 May 2019 IFA Roundtable, Q.2 under Treaties – Income Tax Conventions – Art. 5. ...

CRA indicates that taxpayers can translate under s. 126 foreign taxes at the exchange rate applied to the related income

Summaries of 3 December 2019 CTF Roundtable, Q.2 under s. 126(1) and Treaties – Income Tax Conventions – Art. 24. ...

CRA notes that a capital gain’s geographic source for Canadian FTC purposes was re-sourced to Australia under the Treaty-source rule

Summary of 26 November 2020 STEP Roundtable, Q.4 under Treaties – Income Tax Conventions – Art. 24. ...

CRA is examining whether a server used in cryptocurrency mining is a PE

Although this response was given in a GST/HST context, the same issue would arise regarding the application of income tax conventions. ...

CRA determined that 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

Summary of 25 November 2021 CTF Roundtable, Q.4 under Treaties – Income Tax Conventions – Art. 4. ...

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