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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. ...

.-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Allocation conflict in Sommerer (pp. 289-90) [S]ubsection 75(2)…is an allocation rule that can lead to the income being taxed in the hands of a person resident in Canada. ... [fn 22: OECD, "The Application of the OECD Model Tax Conventions to Partnerships," Issues in International Taxation No. 6 (1999).]… …Case study 16 is based on a situation that resembles one that the Canadian courts had to decide: Example 16 P is a partnership established in State P. ... [fn 23: OECD, "The Application of the OECD Model Tax Conventions to Partnerships," Issues in International Taxation No. 6 (1999), at p. 45.] ...

Kevyn Nightingale, David Turchen, "The US Tax Implications of a Tax-Free Savings Account", CCH Tax Topics, No. 2146, April 25, 2013, p.1, at 2-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Most of the larger accounting firms are taking the conservative position that a TFSA is not treaty-protected.... ... Convention in its application to a U.S. citizen or resident who has a TFSA, they state (at pp. 2-3): The sole remaining question is whether a TFSA is operated "exclusively to provide pension … benefits". ...

Kasper Dziurdź, "Article 15 of the OECD Model: The 183 Day Rule and the Meaning of 'Borne by a Permanent Establishment'", OECD, Bulletin for International Taxation, March 2013, p. 122-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 After reviewing the history of Article 15(2) of the OECD Model Convention, commencing with the Germany-Sweden Income Tax and Capital Treaty (1928), they stated (at p. 124): The object and purpose of the 183-day rule is, therefore, to facilitate the international movement of personnel and the operations of enterprises engaged in international trade. ...

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Re-sourcing of capital gains and derivative gains (p.7) A common scenario in which a treaty re-sourcing rule may apply is where a Canadian resident realizes a capital gain from a disposition of foreign-company shares that is taxable in the company's state of residence under a treaty…. ... Income Tax Convention (the "U.S. Treaty") may also be relevant in the context of payments by Canadian residents under derivative instruments (which would generally be sourced to Canada under Canadian principles) where such payments are subject to U.S. withholding under the recently enacted "dividend equivalent payment" rules in section 871(m) of the Internal Revenue Code (the "Code"). ...

.-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 ...

Calderwood, "The Competent Authority Function: A Perspective from Revenue Canada", 1989 Conference Report, c. 39-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 ...

.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...