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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. ...

CRA finds that amounts retained by a Canadian independent agent to pay its fee constitute amounts "credited" by it to the non-resident principal for withholding tax purposes

., the number of clicks on their ads), the fees would have been subject to withholding under s. 212(1)(d)(iii)(A) of the Act but for a treaty exemption likely being available to the US publisher- such fees for services would not be royalties under the Canada-US Convention. ...

Anson - English Court of Appeal finds that an entity (here, an LLC) generally will not be fiscally transparent if its members have no proprietary interest in its assets

Accordingly, there was no double taxation of the same income when the US taxed the individual's share of the profits of the LLC (which was fiscally transparent for US purposes), and the UK taxed the distribution of those profits: hence, no relief from double taxation under the UK-US Convention. ...

Szymczyk – Tax Court of Canada finds that CRA is entitled to apply provisions with “latitude” rather than strictly

However, her reasons may imply that she would have accepted the taxpayer’s argument that "estoppel by convention" would have applied if there instead had been no material change in circumstances. ...

Starflex – Quebec Court of Appeal indicates that gifts to charities likely cannot be deducted as business expenses

Convention provides (subject to conditions) that a gift by a Canadian with U.S. ...

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