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Veronika Solilová, Marlies Steindl, "Tax Treaty Policy on Article 9 of the OECD Model Scrutinized", OECD, Bulletin for International Taxation, March 2013, p. 128, at 130-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 In the course of reviewing the background to Article 9(2) of the OECD Model Convention, they stated: …According to Working Party 7, article 9 of the OECD Draft (1963) "serves a useful purpose as a statement of what Contracting Parties to Double Taxation Conventions have in Mind". ...

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Discussion of Article IV(7)(b) of the Canada-U.S. Income Tax Convention. ...

Jack Bernstein, "Fiscally Transparent Entities and the Canada-US Treaty", Canadian Tax Highlights, Vol. 20, No. 1, January 2012-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The rules in Articles IV(6) and (7) of the Canada-US Convention might be summarized by stating that if the taxpayer and the fiscally transparent entity reside in the same country, treaty benefits apply. ...

Scott Wilkie, "Services Permanent Establsihments and the Canada-United States Income Tax Treaty", International Transfer Pricing Journal, Vol. 19, No. 3, 2012, p. 179-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Discussion of para. 9 of Art. V of the Canada-US Convention. ...

Finley, "Payments Out of a RCA May Not Be Eligible for Reduced Withholding Tax", Taxation of Executive Compensation and Retirement, September 1990, p. 327-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 RC has accepted that an RCA which has been established in order to fund supplemental pension benefits for an employee is a "superannuation, pension or retirement plan" for purposes of Article XVIII of the U.S. Convention; however, RC will insist on the benefits being available as a result of retirement, and not as a consequence of loss of employment. ...

Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Scope of withholding exemption/reduced withholding for period pension payments (p. 32:15) The Canada-UK treaty…eliminates withholding for periodic pension payments, which may be applicable to certain payments from RRSPs, RRIFs, RCAs and CPP and OAS benefits. "Periodic pension payment" is defined in section 5 of the Income Tax Conventions Interpretation Act as a payment from a pension (for example, a registered pension plan, an RRSP, an RRIF, an RCA, CPP and OAS), subject to certain exceptions. ...

In addition, Article 1 of the Chicago Convention on International Civil Aviation ((1944), 15 U.N.T.S. 295; Canada was and continues to be a party to the convention) provides that "the contracting States recognize that every State has complete and exclusive sovereignty over the airspace above its territory". ...

Current Tax", Volume 23, Number 12, September 2013:-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 Taxpayer's discretion in arbitration (p.138) The MAP [mutual agreement procedure] set out in the Canada-U.S. ... The OECD Model Tax Convention therefore supports a procedure whereby treaty arbitration is engaged only first by a taxpayer, who may then resort to domestic remedies if it is dissatisfied with the result of such arbitration. ...

Hans Pijl, "Agency Permanent Establishments: in the name of and the Relationship between Article 5(5) and (6) – Part 1", Bulletin for International Taxation, January 2013, p. 3:-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 In the course of a detailed review of the law and history of permanent establishments and agency as it relates to the OECD Model Tax Convention, Hans Pijl argues that the history of the OECD Model suggests that, in common law jurisdictions, "in the name of" merely refers to an agency relationship rather than anything stricter: The rise of the "exclusively literal" interpretation of "in the name of" [T]his article revisits the two aspects of the agency PE that are central to the classical articles of Avery Jones and David A. ... Ward, Agents as Permanent Establishments under the OECD Model Tax Convention, 33 Eur. ...