Search - convention
Results 181 - 190 of 8219 for convention
Article Summary
Mateusz M. Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention", Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131. -- summary under Article 9
Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention", Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131.-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 Categories of Cloud-based services (p.132) The models for providing cloud-based services have traditionally been divided into three categories: Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (laaS). ...
Article Summary
Novek, "Convention Expenses Are Subject to Territorial Limitations", Taxation of Executive Compensation and Retirement, February 1992, p. 557. -- summary under Subsection 20(10)
Novek, "Convention Expenses Are Subject to Territorial Limitations", Taxation of Executive Compensation and Retirement, February 1992, p. 557.-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) ...
Article Summary
Leopoldo Parada, "Agents vs. Commissionnaires: A Comparison In Light of the OECD Model Convention", Tax Notes International, October 7, 2013, p. 59 -- summary under Article 5
Commissionnaires: A Comparison In Light of the OECD Model Convention", Tax Notes International, October 7, 2013, p. 59-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 What is a commissionaire arrangement? ...
Article Summary
Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607 -- summary under Article 19
Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 19 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 19 Only cases where taxes have been charged are covered (p. 611) Under the wording of article 19(l)(a) of the MLI, only cases where taxes have actually been charged can be submitted to arbitration…. ...
Article Summary
Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607 -- summary under Article 20
Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 20 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 20 Nature of specific case mutual agreement procedure under OECD Model (p. 609) Once the taxpayer has filed an application for a specific case MAP under article 25(1) of the OECD Model … [t]he procedure…consists of two stages. ...
Article Summary
Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607 -- summary under Article 28(2)
Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 28(2) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 28- Article 28(2) Arbitration reservations are subject to other CTA party’s acceptance (p. 611) Article 28(2)(a) permits the parties to the MLI to formulate one or more reservations with regard to the scope of cases that should be eligible for arbitration under Part VI. ...
Public Transaction Summary
Kingsett & OPB/Primaris -- summary under Unsolicited Bids
US tax consequences If Primaris has made an election to be classified as a partnership for Code purposes, non-resident holders receving distributions from Primaris that are subject to Canadian withholding tax may be denied the benefit of reduced rates under the Canada-US Convention as a result of Art. IV(7)(b) of the Convention. Subject to the PFIC rules, a US unitholder will realized a capital gain or loss on a disposition of units pursuant to the Offer based on the difference the US-dollar value of the Canadian dollars received pursuant to the Offer and the adjusted tax basis of the units. ...
Tax Interpretations Translation
10 October 2003 Roundtable, 2003-0037145 F - CONVENTION DE RETRAITE -- translation
10 October 2003 Roundtable, 2003-0037145 F- CONVENTION DE RETRAITE-- translation ...
Tax Interpretations Translation
14 April 2014 Internal T.I. 2013-0516151I7 F - Article XIII(4) of the Canada-XXXXXXXXXX Convention -- translation
14 April 2014 Internal T.I. 2013-0516151I7 F- Article XIII(4) of the Canada-XXXXXXXXXX Convention-- translation ...
Tax Interpretations Translation
18 May 2011 Internal T.I. 2010-0380391I7 F - Convention entre des co-propriétaires -- translation
18 May 2011 Internal T.I. 2010-0380391I7 F- Convention entre des co-propriétaires-- translation ...