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We have translated 7 more CRA severed letters

Income Tax Act- Section 6- Subsection 6(16)- Paragraph 6(16)(a) per-kilometre rates published by Finance could be used for reasonableness purposes 16 October 2003 External T.I. 2003-0038315 F- CONVENTION DE RETRAITE Also released under document number 2003-00383150. ...

We have translated 7 more CRA severed letters

Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) young child could not claim credit for mother 10 October 2003 External T.I. 2003-0037145 F- CONVENTION DE RETRAITE Also released under document number 2003-00371450. ...

We have translated 6 more CRA interpretations

Bundle Date Translated severed letter Summaries under Summary descriptor 2023-09-06 10 February 2022 External T.I. 2019-0819651E5 F- Pension from China Treaties- Income Tax Conventions- Article 19 pension from China paid to former civil servant now resident in Canada was not exempted under Art. 18 of the Canada-China Treaty 2003-10-03 30 September 2003 External T.I. 2003-0035725 F- MONTANT RELATIF AUX ETUDES Also released under document number 2003-00357250. ...

Husky Energy – Tax Court of Canada finds that a securities loan between residents of two Treaty countries eliminated access to Treaty benefits on the dividend payments

The King, 2023 TCC 167 under s. 212(2), Treaties – Income Tax Conventions – Art. 10, s. 245(1) – tax benefit, s. 245(4). ...

We have translated 8 more CRA interpretations

I tax 27 February 2002 External T.I. 2001-0109675 F- Période admissible et vacance Income Tax Act- Section 122.3- Subsection 122.3(1) period of employment abroad does not include vacation days that could have been taken abroad, but were not 18 March 2002 External T.I. 2002-0120065 F- Avoir fiscal français- 20(11) Income Tax Act- Section 90- Subsection 90(1) French avoir fiscal did not reduce the dividend from a French company required to be included in the resident individual shareholder’s income Treaties- Income Tax Conventions- Article 10 subsequent refund to Canadian shareholder of French avoir fiscal treated as a dividend payment for dividend withholding purposes 2 May 2002 Internal T.I. 2002-0122607 F- BIENS A USAGE PERSONNEL Income Tax Regulations- Regulation 1102- Regulation 1102(2) effective severance for ITA purposes of land and building by Reg. 1102(2) does not apply to personal-use property Income Tax Act- Section 248- Subsection 248(1)- Property where Reg. 1102(2) does not apply, land and building are a single property generating a single gain ...

Singapore Telecom – Federal Court of Australia, Full Court finds that an independent enterprise would have agreed to allow cross-border interest to be capitalized, but not to make it contingent on cash flow

Summary of Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation [2024] FCAFC 29 under Treaties – Income Tax Conventions – Art. 9. ...

Burlington Loan Management – Upper Tribunal finds that Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose

Summary of Revenue & Customs v Burlington Loan Management DAC [2024] UKUT 152 under Treaties – Income Tax Conventions – Art. 12. ...

We have translated 8 more CRA interpretations

Profit- Patents and Know-How the consequences of a sale of IP by a partnership for the benefit of a university and its researchers might be addressed in a ruling 2000-11-10 25 October 2000 External T.I. 2000-0017065 F- CONVENTION DE RETRAITE ET ASSURANCE Income Tax Act- Section 207.6- Subsection 207.6(2) no Pt. ...

S5-F1-C1 - Determining an Individual’s Residence Status

It is the permanence of the home, rather than its size or the nature of ownership or tenancy, that is of relevance. 1.47 For further guidance on the application of the permanent home test, the Courts have referred to the commentary on paragraph 2 of the Article 4 of the Organization for Economic Cooperation and Development Model Tax Convention on Income and on Capital. ... Accordingly, the determination of residency for the purposes of a tax treaty remains a question of fact, and each case should be decided on its own facts with an eye to the intention of the parties of the particular convention and the purpose of international tax treaties. ... To obtain more information, please refer to the current version of Information Circular IC 71-17R5, Guidance on Competent Authority Assistance Under Canada's Tax Conventions. ...

GST/HST Memorandum 3.3 "Place of Supply" April 2000 -- summary under Paragraph 142(1)(a)

Contract governed by the Convention 11. In those cases where the contract between the parties is governed by the United Nations Convention on Contracts for the International Sale of Goods (Convention), the place where the tangible personal property is delivered or made available will have to be determined in accordance with the rules relating to delivery contained in the Convention rather than in accordance with the domestic law of any province. ...

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We have translated 7 more CRA severed letters

We have translated 7 more CRA severed letters

We have translated 6 more CRA interpretations

Husky Energy – Tax Court of Canada finds that a securities loan between residents of two Treaty countries eliminated access to Treaty benefits on the dividend payments

We have translated 8 more CRA interpretations

Singapore Telecom – Federal Court of Australia, Full Court finds that an independent enterprise would have agreed to allow cross-border interest to be capitalized, but not to make it contingent on cash flow

Burlington Loan Management – Upper Tribunal finds that Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose

We have translated 8 more CRA interpretations

S5-F1-C1 - Determining an Individual’s Residence Status

GST/HST Memorandum 3.3 "Place of Supply" April 2000 -- summary under Paragraph 142(1)(a)

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