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Results 1881 - 1890 of 8209 for convention

CRA considers that a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. IV(6) for the 5% Treaty-reduced rate on dividends to its U.S. parent

Summaries of 18 April 2019 Internal T.I. 2018-0753621I7 under Treaties – Income Tax Conventions – Art. 10, Art. 4, s. 247(12). ...

5 more translated CRA interpretations are available

Bundle Date Translated severed letter Summaries under Summary descriptor 2010-09-17 25 August 2010 External T.I. 2010-0374231E5 F- Safe income allocation Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income required to be allocated to prefs and new common shares received on a s. 51 exchange even where the redemption amount of the prefs matched the amount of such safe income General Concepts- Fair Market Value- Shares Compliance Programs Branch now providing advance guidance on valuation methodology 2010-09-10 17 August 2010 External T.I. 2010-0367371E5 F- Fin d'un usufruit- résidence principale Income Tax Act- Section 248- Subsection 248(3) dissolution of s. 248(3) trust when the usufructuaries renounced their right of usufruct Income Tax Act- Section 54- Principal Residence- Paragraph (a.1) usufructuary parents were specified beneficiaries based on their inhabiting the housing unit Income Tax Act- 101-110- Section 107- Subsection 107(2.01) deemed s. 248(3) trust that dissolved when the usufructuary parents renounced their, makes a s. 107(2.01) or (2.001) to apply principal residence exemption to dissolution gain 12 August 2010 External T.I. 2010-0360171E5 F- Déclaration T-1135 et biens étrangers Income Tax Act- Section 233.2- Subsection 233.2(1)- Exempt Trust exempt foreign trust definition contains strict conditions Income Tax Act- Section 233.3- Subsection 233.3(1)- Specified Foreign Property- Paragraph (n) Swiss vested benefits account was not exempted 24 August 2010 External T.I. 2010-0354791E5 F- Commission d'un non-résident- 105(1) RIR Income Tax Regulations- Regulation 105- Subsection 105(1) fee for services performed wholly in UK re sale of Canadian real estate not subject to withholding 19 August 2010 External T.I. 2009-0344111E5 F- Résidence Société Capital-Risque- Conv Can-France Treaties- Income Tax Conventions- Article 4 French venture capital corporation is resident in France (“liable to tax”) notwithstanding that it has elected to be exempt on its portfolio gains ...

CRA publishes administrative relief for COVID-19 impact on international transactions and status

Summaries of Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 19 May 2020 under s. 2(1), Treaties – Income Tax Conventions – Art. 5, Art. 15, s. 2(3)(b), s. 153(1.1), Reg. 105(1), s. 116(1). ...

Joint Committee suggests more detailed scoping of the CRA’s COVID-19 relieving positions on international transactions

Summaries of Joint Committee, “Guidance on International Income Tax Issues raised by the COVID-19,” 11 June 2020 Joint Committee Submission under Reg. 5907(1) – exempt earnings – (d). s. 95(1) – FAPI, Treaties – Income Tax Conventions – Art. 5, s. 153(6). ...

CRA publishes its position on the Treaty exemption for Roth IRA income and distributions

Summaries of Income Tax Folio S5-F3-C1, Taxation of a Roth IRA under s. 56(1)(a)(i)(C.1), s. 94.2(1), Treaties – Income Tax Conventions – Art. 18 and s. 233.3(3). ...

Our translations of CRA Interpretations go back over 11 years

.- frais de garde Treaties- Income Tax Conventions- Article 19 employment income that was Treaty-exempt was to be reported (on a separate line), with the s. 110(1)(f)(i) deduction then claimed Income Tax Act- Section 63- Subsection 63(2) child care expenses could only be claimed by the spouse with the lower net income, notwithstanding that her income was Treaty-exempt ...

We have translated 5 more CRA Interpretations

Bundle Date Translated severed letter Summaries under Summary descriptor 2009-06-12 27 May 2009 Internal T.I. 2009-0320311I7 F- CELI- Notion d'avantage Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(ii) accretion in common shares issued to employee's TFSA on an estate freeze was an advantage 3 June 2009 External T.I. 2009-0319551E5 F- Déductibilité des dépenses Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit test for identifying a business source 2009-06-05 26 May 2009 External T.I. 2009-0316841E5 F- Convention de retraite, crédit d'impôt étranger Income Tax Act- Section 126- Subsection 126(1) no foreign tax credit can be claimed for non-business income tax paid on income of RCA trust Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax- Paragraph (b) usual Pt. ...

Landbouwbedrijf Backx – Tax Court of Canada finds that Dutch legal expert testimony was required in order to establish dual corporate residency

The Queen, 2021 TCC 2 under s. 128.1(1)(c), Treaties – Income Tax Conventions- Art. 4 and General Concepts- Estoppel. ...

G E Financial Investments – First-Tier Tribunal finds that a deemed US resident was not a US treaty resident

The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (TC) under Treaties – Income Tax Conventions – Art. 4, Art. 5. ...

Addy – High Court of Australia finds that imposing higher tax on Australian residents who were visa holders than on those who were not, violated a Treaty non-discrimination Article

Summary of Addy v Commissioner of Taxation [2021] HCA 34 under Treaties – Income Tax Conventions – Art. 25. ...

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