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Income Tax Technical News No. 44 13 April 2011 [archived] -- summary under Article 10

Income Tax Technical News No. 44 13 April 2011 [archived]-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 use of s.à r.l. ...

[U.K] Revenue and Customs Brief 15 (2015): HMRC response to the Supreme Court decision in George Anson v HMRC (2015) UKSC 44 25 September 2015 -- summary under Article 24

[U.K] Revenue and Customs Brief 15 (2015): HMRC response to the Supreme Court decision in George Anson v HMRC (2015) UKSC 44 25 September 2015-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Anson specific to its facts …[T]he [Anson] decision is specific to the facts found in the case. ...

5 April 2015 CRA Press Release (respecting Panama Papers) -- summary under Article 27

5 April 2015 CRA Press Release (respecting Panama Papers)-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 CRA will communicate with Treaty partners to obtain any missing Panama Papers Recent media coverage raises questions about leaked documents from a Panama law firm relating to the offshore financial affairs of numerous individuals worldwide....The Agency is actively pursuing the cooperation of its tax treaty partners and the International Consortium of Investigative Journalists to obtain all of the leaked records that pertain to Canadian residents. ...

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority -- summary under Paragraph 247(2)(d)

TPM-2, on secondary adjustments and repatriation, which is in its final stages of approval, and CRA is working on TPM-3, dealing with downward adjustments, in conjunction with updates to IC 71-17, Guidance on Competent Authority under Canada’s Tax Conventions. ...

Wolf v. The Queen, 2018 TCC 84, aff'd on evidentiary grounds 2019 FCA 283

Pursuant to paragraph 9 of Article V of the Convention, the income earned by Mr. ... Subparagraph 9(a) of Article V of the Convention reads as follows: 9. ... In order to do so, the Court must determine whether, under the Convention, Mr. ...

Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2020 FC 893

Article 26 of the Convention, under the heading “Exchange of Information”, reads as follows: 1. ... For the Convention to apply to the Trusts, the settlor must be domiciled in France, the trust property must be situated in France, or the Trusts must be residents of France within the meaning of the Convention, none of which are the case here. ... Moreover, the Convention cannot give more powers to a State than it would have under its domestic law. ...

Taylor v. Canada, docket T-3058-90

Income Tax Convention (1980), more particularly subparagraphs 4(a) and (b) of article XXIV which provide as follows: 4. ... Under the terms of the Convention, the Minister is obligated to allow a deduction from tax in respect to profits, income or gains which arise or are deemed to arise in the U.S. ... JUDGE OTTAWA, Ontario July 20, 2000__________________ 1 S.C. 1970-71-72, c. 63. 2 Convention with respect to taxes on income and on capital, signed at Washington on September 26, 1980. ...

Deegan v. Canada (Attorney General), 2019 FC 960, aff'd 2022 FCA 158

T.S. 1984 No. 15 (as implemented by the Canada-United States Tax Convention Act, 1984, S.C. 1984, c. 20) (the Canada-U.S. ... Tax Treaty provides that the competent authorities of the contracting States “shall exchange such information as may be relevant for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes to which this Convention applies …”. ... Incompatibilité — exception (2) Les dispositions de la Loi sur l’interprétation des conventions en matière d’impôts sur le revenu l’emportent sur les dispositions incompatibles de l’Accord. ...

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter' - Subsection 237.1(1) -- summary under Article 29A

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter'- Subsection 237.1(1)-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A sale of shares of USco carrying on parallel business Assume that USco carries on an active business in the United States (other than an investment business). ...

Transfer Pricing Memorandum TPM-06, “Bundled Transactions” 16 May 2005 -- summary under Article 12

Transfer Pricing Memorandum TPM-06, “Bundled Transactions” 16 May 2005-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 distinction between know-how and services provision After noting the exemption in Art. 12 of the Canada-U.S. ...

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