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IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Where the treaty does not contain a specific article on management or administration fees, such fees paid to the non-resident will, to the extent they are reasonable, be considered to be covered by the business profits article. ...

IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 Where an individual is present in Canada for a period not exceeding 60 days and is not entering Canada on a recurring basis, the individual will not be considered to have a fixed base in Canada. ...

Round Table, Q. 44-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "The Department usually considers that, where the Canadian activities of a foreign business are carried on through an organized and structured sales force, the sales force may represent for the non-resident sufficient substantial presence in Canada to be considered a permanent place of business and thus a permanent establishment. ...

4 March 1993 Memorandum (Tax Window, No. 30, p. 18, ¶2472)-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 A Canadian resident will not be entitled to a foreign tax credit or to a refund of ACT from the U.K. authorities with respect to a stock dividend received from a U.K. corporation. ...

.- Q.57-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax To the extent that a tax-sparing provision within a Convention deems an amount to have been paid to the government of a foreign country, the taxes spared will qualify as a "non-business income tax. ...

.- Q.57-- summary under Subsection 20(12) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(12) Treaty inapplicability As s. 20(12) provides for a deduction from income and not from tax, Conventions which provide for "a deduction from the tax on the income of that person" for taxes that have been spared will not render s. 20(12) applicable. ...

IC-6R2 para. 95 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 CRA has adopted the OECD position that the words "borne by" mean that the expenses allowable as a deduction in computing taxable income. ...

Alternative Minimum Tax")-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Discussion of double taxation situation where a U.S. citizen who is resident in Canada and earning only Canadian-source income is subject to U.S. alternative minimum tax. ...

.- Q.4-- summary under Paragraph 250(1)(a) Summary Under Tax Topics- Income Tax Act- Section 250- Subsection 250(1)- Paragraph 250(1)(a) A U.S. resident who sojourns in Canada for 183 days or more will be required to report his world income, will be entitled to deduct amounts exempted by the Convention, and will be entitled to claim full personal exemptions. ...

.- Q. 29-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A payment to a non-resident for the use of, or the right to use, a custom computer software program for a period of indefinite duration is subject to tax under s. 212(1)(d)(i). ...