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S5-F3-C1 - Taxation of a Roth IRA -- summary under Article 18

S5-F3-C1- Taxation of a Roth IRA-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Basic U.S. ...

Granite -- summary under Cross-Border REITs

Non-resident unitholders It is unclear whether qualifying U.S. residents (who otherwise would benefit under Article XXII of the Canada-US Convention from the 0% withholding tax rate applicable to distributions made out of income arising outside Canada, and a 15% rate applicable to income arising in Canada) would have that benefit denied under the anti-hybrid rule in Art. ...

Starlight No. 5 -- summary under Foreign Asset Income Funds and LPs

However, the CRA's administrative practice in similar circumstances is to permit the rate of Canadian federal withholding tax applicable to such payments to be computed by looking through a partnership and taking into account the residency of its partners (including partners who are resident in Canada) and any reduced rates of Canadian federal withholding tax that any non-Canadian limited partners may be entitled to under an applicable income tax treaty or convention, provided that the residency status and entitlement to treaty benefits can be established. ...

17 May 2023 IFA Roundtable - Official Response

Question 4: Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ... Income Tax Convention (the “Treaty”) and is entitled to benefits under the Treaty (i.e., USco is a “qualifying person” for purposes of Article XXIX-A of the Treaty). ... Income Tax Convention (“the Treaty”). US LLC 1 makes an interest bearing loan to US LLC 2. ...

Canada-U.S. Income Tax Convention - Agreement between Competent Authorities on the interpretation of Article VII (Business Profits) CRA Notice dated 19 July 2012 -- summary under Article 7

Income Tax Convention- Agreement between Competent Authorities on the interpretation of Article VII (Business Profits) CRA Notice dated 19 July 2012-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 The competent authorities of Canada and the US agreed on 26 June 2012 pursuant to Article XXVI, para. 3 (resolution of interpretive doubt), that Article VII of the Canada-US Income Tax Convention is to be interpreted consistently with the OECD 2010 Report on the Attribution of Profits to Permanent Establishments. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 34. -- summary under Foreign Convention

.-- summary under Foreign Convention Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Foreign Convention relevance of prior conference stats to determination How does a taxpayer determine the number of non- resident attendees to attend a foreign convention if it has not yet occurred? ... …[F]or this year's convention in Calgary, Alberta, it would not be reasonable to just use the attendance from the Australian conference…. A reasonable method…would likely consider more historical attendance data and an analysis of who attends or who does not attend their conventions based on the geographical proximity of the convention venue with the location of society members. ...

Information Circular IC76-12R8 Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention -- summary under Subsection 212(1)

Information Circular IC76-12R8 Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention-- summary under Subsection 212(1) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1) Due diligence requirements re payers ¶ 20. ... If a payer has reason to believe that a limiting provision in the relevant tax convention will restrict the application of treaty benefits, the payer must either withhold the full 25% tax or obtain certification from the recipient stating that they are eligible for treaty benefits. ¶ 22. ...

Tréport Wedding and Convention Centre Ltd. v. The Queen, 2015 TCC 203

Tréport Wedding and Convention Centre Ltd. v. The Queen, 2015 TCC 203 Docket: 2013-4298(EI) BETWEEN: LE TRÉPORT WEDDING AND CONVENTION CENTRE LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Docket: 2013-4300(CPP) BETWEEN: LE TRÉPORT WEDDING AND CONVENTION CENTRE LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... CITATION: 2015TCC203 COURT FILE NO.: 2013-4298(EI) 2013-4300(CPP) STYLE OF CAUSE: LE TRÉPORT WEDDING AND CONVENTION CENTRE LTD. ...

21 May 2014 CBA Roundtable

Non-resident conventions Summary of Question How does a taxpayer determine the number of non- resident attendees to attend a foreign convention if it has not yet occurred? ... Section 189.2 deems certain supplies by a sponsor of a foreign convention, including admissions to the foreign convention, to have been made otherwise than in the course of a commercial activity of the sponsor. ... In planning for this year’s convention in Calgary, Alberta, it would not be reasonable to just use the attendance from the Australian conference to determine whether the convention in Calgary will be a foreign convention or not, considering the attendance data for the Seattle convention and the geographical distances involved. ...

6 October 2017 APFF Roundtable

Official response 6 October 2017 APFF Roundtable Q. 11, 2017-0709091C6 F- Transitional rules- Class 14.1 Q.12 Two-convention limitation where business expense The two-convention limitation in s. 20(10) applies only to capital expenditures. Are expense of attending conventions which were incurred for earning income from a business not subject to this limitation? ... Historically, the CRA's position with respect to convention expenses is that such expenditures are generally capital expenditures to which paragraph 18(1)(b) applies. ...

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