27 July 2016 External T.I. 2015-0603271E5 - Subsection 216.1(1) and permanent establishment
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|Tax Topics - Treaties - Income Tax Conventions - Article 16||Art. 16 of US Treaty permits gross withholding taxation even if PE||172|
|Tax Topics - Income Tax Act - Section 115 - Subsection 115(2.1)||prohibition against acting income being filed on a net basis in absence of timely s. 216.1 election||105|