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Canadian residents generally are better off investing in a portfolio that may include Canadian companies through a partnership rather than an LLC

Summary of Nakul Kohli and Jiani Qian, “Canadian Residents Earning Income Through Non-Resident US LLCs,” Canadian Tax Focus, Vol. 12, No. 1, February 2022, p. 10 under Treaties – Income Tax Conventions – Art. 4. ...

CRA indicates that “habitual abode” is determined in context based inter alia on relative stays and nature of activities

Summaries of 17 May 2022 IFA Roundtable, Q.1 under Treaties- Income Tax Conventions – Art. 4 and ITA s. 2(1). ...

CRA notes that around half of its recent MAP cases resulted in full relief

Summary of 17 May 2022 IFA Roundtable, Q.13 under Treaties – Income Tax Conventions – Art. 26. ...

CRA finds that where a UK company remotely operated crypto-mining equipment located on a Canadian host company’s premises, the equipment constituted a Canadian PE

Summary of 29 November 2022 CTF Roundtable, Q. 7 under Treaties – Income Tax Conventions – Art. 5. ...

Finance confirms that Pillar 2 is on track

The legislation is being drafted using Canadian legislative drafting conventions, but seeks to follow the OECD model closely. ...

CRA indicates that CPP and OAS payments are treated as pensions and social security payments under the Canada-Italy Treaty

Summary of 6 April 2023 Internal T.I. 2022-0929731I7 under Treaties – Income Tax Conventions – Art. 18. ...

CRA indicates that an exceptional COVID-related withdrawal from a Chilean pension plan qualified as an exempted pension under the Canada-Chile Treaty

Summary of 12 December 2023 External T.I. 2021-0881541E5 under Treaties – Income Tax Conventions – Art. 18. ...

CRA rules that a French société civile de placement immobilier (SCPI) is a corporation

6 November 2024- 10:59pm CRA rules that a French société civile de placement immobilier (SCPI) is a corporation Email this Content CRA ruled that a société civile de placement immobilier (“SCPI”) [real estate investment company] was a corporation for ITA purposes and a “company” for purposes of the Canadian application of the Convention with France. ...

CRA indicates that Reg. 8503(26) minimum amount payments or commutation payments are lump sums ineligible for reduction under Canada-U.S. Treaty

CRA rejected the taxpayer submission that the IPP winding-up distribution was “simply an extension of the periodic guarantee payments,” and found that, since it was a lump sum payment as referenced in the definition of “periodic pension payment” in s. 5 of the Income Tax Conventions Interpretation Act, it was subject to withholding at 25%. ...

CRA takes pragmatic approach to meaning of “regularly traded” under the Canada-U.S. Treaty?

Technical Explanation states that "subject to the adoption by Canada of other definitions, the U.S. interpretation of ‘regularly traded’ and ‘primarily traded’ will be considered to apply, with such modifications as circumstances require, under the Convention for purposes of Canadian taxation. ...

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