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CRA finds that the Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them

Summary of 7 June 2017 Canadian Petroleum Tax Society Roundtable, Q.3 under Treaties – Income Tax Conventions – Art. 13. ...

CRA finds that Art. IV(6) of the Canada-US Treaty works to reduce Canadian branch profits tax earned through multiple stacked LLCs

Summary of 4 April 2019 Internal T.I. 2017-0736531I7 under Treaties – Income Tax Conventions – Art. 4. ...

CRA seemingly indicates that contingent interest under Art. XI(6)(b) of the US Treaty does not taint any contemporaneous fixed interest

Summary of 15 May 2019 IFA Roundtable, Q.3 under Treaties – Income Tax Conventions – Art. 11. ...

CRA indicates that the Art. XXIX-A(3) Canada-US LOB clause exclusion would be unavailable to income derived by a Canadian subsidiary from an offshore connected-business FA

Summary of 15 May 2019 IFA Roundtable, Q.8 under Treaties – Income Tax Conventions- Art. 29A. ...

Retfalvi – U.S. 4th Circuit finds that Art. 26A of the Canada-U.S. Treaty was constitutionally valid

., 4 th Circuit, 16 July 2019) under Treaties – Income Tax Conventions- Art. 26A. ...

CRA considers that a Treaty exemption for income does not preclude being an eligible entity for CEWS purposes

Accordingly, CRA has concluded: [A] non-resident corporation that operates an airline, a portion of whose Canadian source income is not included in the computation of its income under Part I of the Act as a result of the operation of paragraph 81(1)(a) and a provision under an income tax convention between Canada and another State is not a corporation “exempt from tax under Part I” under the definition of “eligible entity” in subsection 125.7(1) and therefore would not be prevented from being an “eligible entity” on that basis. ...

Fowler – UK Supreme Court finds that deeming an employee to be an independent contractor did not oust the Treaty Employment-Income Article

Summary of Fowler v Commissioners for Her Majesty’s Revenue and Customs [2020] UKSC 22 under Treaties – Income Tax Conventions- Art. 3 and Statutory Interpetation – Interpretation Provisions. ...

Samsung Heavy Industries – Supreme Court of India finds that a Mumbai liaison office for a domestic construction project was not a PE

Samsung Heavy Industries Co Ltd (Supreme Court) CIVIL APPEAL NO. 12183 of 2016 under Treaties – Income Tax Conventions – Art. 5. ...

Pike – Federal Court of Australia, Full Court finds that an individual had his centre of vital interest where he was employed, rather than where he had his greater personal ties

Summary of Commissioner of Taxation v Pike [2020] FCAFC 158 under Treaties – Income Tax Conventions – Art. 4. ...

CRA indicates that where Canco is held by fiscally transparent Franceco, which is held by LP with only some US partners, there is a choice as to which Treaty to apply

Summary of 27 October 2020 CTF Roundtable, Q.5 under Treaties – Income Tax Conventions – Art. 4. ...

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