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Post-Anson, CRA maintains its position of no foreign tax credit for U.S. taxes paid by a Canadian member on undistributed LLC income

In particular, after noting that the OECD Commentary on Art. 23B of the Model Convention “expressly contemplates that states may impose timing restrictions on claiming foreign tax credits,” and that where this is so “these countries…would be expected to seek other ways…to relieve the double taxation which might otherwise arise in [such] cases,” CRA stated: In the case of Canada, such “other ways … to relieve the double taxation” include deductions allowed under subsections 20(11) and 20(12) of the Act. ...

Formula One decision departs from jurisprudential and OECD standards of what is a PE

Summary of Richard Tremblay and Ilana Ludwin, "Indian Supreme Court Diverges from OECD Guidelines, Relies on Questionable Canadian Precedent, in Deciding PE Issue in Formula One," Tax Management International Journal, 2018, p. 125 under Treaties – Income Tax Conventions- Art. 5. ...

Davis – Tax Court of Canada finds that an individual who was well advanced in his steps to return to Canada had a “habitual abode” in the U.S.

The Queen, 2018 TCC 110 under Treaties – Income Tax Conventions- Art. 4. ...

Where an LLC has a Canadian business, it may be advantageous for U.S. members to hold their membership interests through S Corps

Summary of Julie Colden and Éric Lévesque, “An In-Depth Look at the Hybrid Rules in the Fifth Protocol,” 2017 Annual CTF Conference draft paper under Treaties – Income Tax Conventions – Art. 4. ...

CRA treats non-resident LPs as conduits for purposes of Treaty interest withholding relief

Summary of 2017 Ruling 2017-0712731R3 under Treaties – Income Tax Conventions – Art. 11. ...

CRA finds that a US LLC did not have a Canadian PE where a former employee serviced its U.S. clients from his Canadian home office under pass-through payroll arrangement

Summary of 2018 Ruling 2017-0713071R3 under Treaties – Income Tax Conventions – Art. 5. ...

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. ...

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