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" LEGISLATION- CARRYING ON BUSINESS 24(1) CANADA-US INCOME TAX CONVENTION 24(1) We understand that Article VII of the Canada-US Income Tax Convention (1980) ("Treaty") confirms the Treaty partner's intent that this Article has application in circumstances where "the resident carries on, or has carried on, business" in the other Contracting State. ...

Income Tax Convention We are writing in response to your email dated May 15, 2020, requesting our views on the interpretation of the phrase “such use is for more than three months in any twelve-month period” contained in Article V(4) of the Canada-U.S. Income Tax Convention (the “Canada-U.S. Treaty”). In particular, you requested our views as to whether the term “three months” refers to a consecutive period, whether “three months” means three calendar months or days totaling an equivalent of three months, and whether the word “use” includes standby time and preparation time. ...

Convention fiscale entre le Canada et les É.-U.: Organisations exonérées 33. ... Le Protocole joint à la Convention en matière d'impôts sur le revenu conclue entre le Canada et les Pays-Bas renferme une exemption de ce genre. ... En vertu de la convention fiscale, cette corporation non résidante n'est pas assujettie à l'impôt de la partie I au Canada. ...

Reasons: Wording of paragraph 3 of Article XXIX A. 2010 Canadian Tax Foundation Conference November 28, 2010 Article XXIX A(3) of the Canada-US Income Tax Convention Question 12 Can the CRA comment on whether interest paid by Canco (a Canadian corporation) to its parent USco (a non-qualifying person) on a debt owing to USco would be eligible for benefits pursuant to article XXIX A(3) of the treaty (the "active conduct of a trade or business" test)? ...

Income Tax Convention (the "Treaty") This is in reply to your letter of October 28, 1992 and further to our telephone conversation (XXXXXXXXXX/Middleton) wherein you requested our opinion on whether there was a Canadian PE under Article V of the Treaty in the particular situation described in your letter. ...

Wilson  Division 957-2063 Attention:  Ken Major File No. 90M02429 Chief, Foreign Section 24(1)- SECURITY LENDING REVENUE CANADA- UNITED KINGDOM INCOME TAX CONVENTION We are writing in regard to an interpretation of Article XI, sub-paragraph 4(a) and paragraph 5 of the above-noted treaty.  24(1) has requested confirmation as to the tax treatment of income received by the 24(1) as compensation for Canadian Government Bonds loaned pursuant to a securities lending arrangement. 24(1) is of the opinion that the treaty exempts this income from Part XIII tax (copy of letter attached). ...

19 April 2012 Internal T.I. 2012-0436221I7- LLCs and ULCs and Treaty benefits Unedited CRA Tags Articles IV(6) and IV(7) of the Canada-United States Income Tax Convention Principal Issues: 1. Whether a single member limited liability company ("LLC") created pursuant to the laws of the United States (“U.S.”) which is treated as a disregarded entity for U.S. tax purposes, is entitled to the benefits of the Canada-United States Income Tax Convention ("Treaty")? ... April 19, 2012 Janet Schermann HEADQUARTERS Non-Resident Policy Advisor Income Tax Rulings 112 Kent St., room 1929 Directorate Place de Ville, Tower B Angelina Argento Ottawa, Ontario, K1A 0L5 2012-043622 Limited liability company ("LLC"), unlimited liability company (“ULC”) and the Canada-United States Income Tax Convention ("Treaty”) This is further to your email request of February 9, 2012 wherein you asked for suggested wording to be added to the CRA website which would address the following issues: 1. ...

2020 Ruling 2019-0801011R3- Article 13(4) of the Treaty Unedited CRA Tags 2(3), 69, 115, 116, 248(1) "taxable Canadian property" & "treaty-protected property", Canada-XXXXXXXXXX Income Tax Convention, Income Tax Conventions Interpretation Act, XXXXXXXXXX, Interpretation Act Principal Issues: Whether a capital gain on the disposition of shares of a XXXXXXXXXX. resident corporation by a XXXXXXXXXX resident individual is subject to tax in Canada where the value of the shares is derived principally from immovable property situated in Canada. ... XXXXXXXXXX 2019-080101 XXXXXXXXXX, 2020 Dear XXXXXXXXXX, Re: Advance Income Tax Ruling – Disposition of Shares and the Application of Article 13 of the Canada-XXXXXXXXXX Income Tax Convention This is in reply to your letter dated XXXXXXXXXX in which you requested an advance income tax ruling (the “Ruling”) on behalf of the above-named Taxpayer. ...

Internal Revenue Code (Inverted Payer Corporation) to: a. a corporation resident of the US that is entitled to treaty benefits under the Canada-US Income Tax Convention (Treaty); b. another Inverted Payer Corporation (incorporated in Canada); c. a Canadian resident taxpayer; d. a resident of a country other than Canada or the US (without regard to any applicable treaty provisions). 2. ... Angelina Argento Compliance Programs Branch 2022-093626 Application of the Canada-US Income Tax Convention to expatriated entities This is in response to your request for a technical interpretation dated May 13, 2022, wherein you requested our views on the Canadian withholding obligations in respect of certain amounts paid or credited by a corporation incorporated under the laws of Canada that is subject to the so-called “anti-inversion rules” set forth in §7874(b) of the Internal Revenue Code of the United States of America (Inverted Payer Corporation) (footnote 1). ... That rate may be reduced by the provisions of an Income Tax Convention between Canada and the country of residence of the recipient of the Payments. ...

The shares of NRO are owned by an entity resident in a country that has no tax convention with Canada. ... Specifically, does the Department consider that the gain is exempt pursuant to paragraph 4 of Article XIII of the Convention? ... Revenue Canada response 1)      In preparing a response we have assumed that Canco does not derive the value of its shares principally from real property situated in Canada for the purposes of Article XIII(3) of the Canada-United States Tax Convention (hereafter "the Convention") or from the alienation of personal property as indicated in Article XIII(2) of the Convention.       ...