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Canada v. Bioartificial Gel Technologies (Bagtech) Inc., 2013 DTC 5155 [at at 6361], 2013 FCA 164

Définitions « convention unanime des actionnaires » “unanimous shareholder agreement” « convention unanime des actionnaires » Convention visée au paragraphe 146(1) ou déclaration d’un actionnaire visée au paragraphe 146(2). 145.1 Des actionnaires peuvent conclure entre eux une convention écrite régissant l’exercice de leur droit de vote. 146. (1) Est valide, si elle est par ailleurs licite, la convention écrite conclue par tous les actionnaires d’une société soit entre eux, soit avec des tiers, qui restreint, en tout ou en partie, les pouvoirs des administrateurs de gérer les activités commerciales et les affaires internes de la société ou d’en surveiller la gestion ... (3) L’acquéreur ou le cessionnaire des actions assujetties à une convention unanime des actionnaires est réputé être partie à celle-ci ... (6) Il est entendu que le présent article n’empêche pas les actionnaires de lier à l’avance leur discrétion lorsqu’ils exercent les pouvoirs des administrateurs aux termes d’une convention unanime des actionnaires. ...

Her Majesty the Queen v. Saint John Shipbuilding & Dry Dock Co LTD, [1979] CTC 380, 79 DTC 5297

In addition to disputing liability under the aforementioned sections of the Statute defendant relies on Articles I and II of the Canada-US Tax Convention and Clause 6(a) of the Protocol thereto and the Canada-United States of America Tax Convention Act, 1943-44 S of C c 21. ... Subject to the provisions of this Convention such items of income shall be taxed separately or together with industrial and commercial profits in accordance with the laws of the contracting States. and clause 6(a) of the Protocol defines the term “rental and royalties’’ referred to in Article Il of the Convention in the following manner: The term “rental and royalties” referred to in Article II of this Convention shall include rentals or royalties arising from leasing real or immovable, or personal or movable property or from any interest in such property, including rentals or royalties for the use of, or for the privilege of using, patents, copyrights, secret processes and formulae, goodwill, trade marks, trade brands, franchises and other like property. ... I also conclude therefore that under the provisions of the Canada- US Tax Convention the payments made were not subject to the deduction of withholding tax as required by subsection 215(6) of the Act. ...

26 May 2016 IFA Roundtable Q. 2, 2016-0642061C6 - AOA & Notional Expenses

This report was revised in 2010 in order to be read harmoniously with the new wording of Article 7 of the OECD’s Model Tax Convention on Income and Capital (“Model Convention”) and its related commentary. ... This position is essentially based on our view that paragraph 4(b) of the Income Tax Conventions Interpretation Act (“ITCIA”) prevents such deductions. ... In respect of the Canada – United Kingdom Tax Convention, we would note that the new AOA-based Article 7 language was included in the convention by virtue of the protocol signed on July 21, 2014. ...

8 September 1998 External T.I. 9820085 - ARGENTINA TAX ON RENTAL OF SOFTWARE

Position: Article 12 of Canada-Argentina Income Tax Convention dealing with royalties. Reasons: Article 12 of Canada-Argentina Income Tax Convention XXXXXXXXXX 982008 G. ... The above comments are based on our understanding of the facts and reflect our interpretation of the laws in the Act and the Convention. ...

14 September 1993 Income Tax Severed Letter 9313615 - Tax a Partner of a Foreign Partnership

Harding (613) 957-2111 September 14, 1993 Dear Sirs: Re: Canada-Egypt Income Tax Convention (the "Convention") This is in reply to your letter which was faxed to Revenue Canada on May 10, 1993 wherein you requested our opinion concerning the taxability of income earned by a Canadian partner as a member of an Egyptian partnership which carries on business only in Egypt. ... It is your view that paragraph 1 of Article 7 of the Convention will take precedence over the Income Tax Act and prevent Canada from taxing the income of a partnership in such a situation. Paragraph 6.2 of the Income Tax Conventions Interpretation Act (the "ITCIA") was enacted to clarify that Canada maintains its right to tax the Canadian partners on their share of income of a partnership which may be considered a resident or enterprise of the other country under a tax convention or agreement. ...

27 March 2003 External T.I. 2002-0155705 - PENSION INCOME US SOURCE

Income Tax Convention (the "Convention"). Our Comments Opinions concerning proposed transactions involving specific taxpayers will only be provided in response to a request for an advance income tax ruling. ... Once you retire your U.S. government pension will no longer be subject to the provisions of Article XIX of the Convention. ... Instead, your U.S. source pension income will be subject to the provisions of Article XVIII of the Convention. ...

8 April 2003 External T.I. 2003-0001995 - Value or the greater part of their value

Cook April 8, 2003 Re: Technical Interpretation Request Dear XXXXXXXXXX: We are writing in reply to your letter of February 6, 2003, in which you requested our interpretation of the term "value or the greater part of their value" as used in paragraph 5(a) of Article 13 of the Canada-United Kingdom Income Tax Convention (1978) (the "Convention"). ... We note that neither the term "value or the greater part of their value" or any portion of the term is defined in the Convention. Similarly, no particular meaning is mandated by section 3 of the Income Tax Conventions Interpretation Act. ...

5 June 1989 Income Tax Severed Letter AC57796 - Withholding Tax on Films/Videotapes

Income Tax Convention (Convention) which states "...copyright and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work, including royalties from such works on videotape...for private (home) use... ... Although it is our position that payments for motion pictures are not generally treaty-exempt, motion pictures that are on videotape and are provided for private (home) use would fall within the exemption set out in paragraph 3, Article XII of the Convention. ... In our view, as long as Canco can ensure that the videotape cassette can only be used for the private (home) use, he will be entitled to the deduction provided in paragraph 3 of Article XII of the Convention. ...

1 May 1989 Income Tax Severed Letter 7-3797 - [U.S. Estate Tax]

Income Tax Convention (the "Convention"). It is our view that the U.S. ... The Technical Explanation to the Convention clearly indicates that the "... taxes not generally covered by the Convention include, in the case of United States, the estate... taxes... ... Accordingly, the Convention will not provide any relief to the deceased estate with respect to U.S. ...

7 September 1990 Income Tax Severed Letter - Determination of the georgraphical source of stock option benefits to determine which country will grant a foreign tax credit

In addition, please confirm whether paragraph 3 of Article XXIV of the Canada-United States Income Tax Convention, 1980 (the "Convention"), which provides for source rules for the purposes of applying that article, would force both countries to adopt the same sourcing rules for the application of the Convention. ... Our opinion as to the territorial source of income constituted by a benefit derived from an employee stock option as set forth above applies in respect of situations covered by the Canada- United States Income Tax Convention, 1980. ... Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the Convention, the person may apply to the competent authority pursuant to Article XXVI of the Convention which provides a mechanism whereby such actions can be considered by the Contracting States with a view to avoiding by agreement of the Contracting States taxation which is not in accordance with the Convention. ...

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