Cases
Canada v. Prévost Car Inc., 2009 DTC 5721, 2009 FCA 57
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|---|---|---|
| Tax Topics - Treaties | 76 |
Hunter Douglas Ltd. v. The Queen, 79 DTC 5340, [1979] CTC 424 (FCTD)
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| Tax Topics - Treaties | 47 |
See Also
RMM Canadian Enterprises Inc. v. The Queen, 97 DTC 302, [1998] 1 C.T.C. 2300 (TCC)
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Specialty Manufacturing Ltd. v. The Queen, 97 DTC 1511 (TCC)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(4) | 48 |
Administrative Policy
27 October 2020 CTF Roundtable, Q.5
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| Tax Topics - Treaties - Income Tax Conventions - Article 4 | where Canco is held by fiscally transparent Franceco, which is held by LP with only some US partners, there is a choice as to which Treaty to apply | 374 |
18 April 2019 Internal T.I. 2018-0753621I7 - Subsection 247(12)
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| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(12) | transfer pricing income adjustment re sale to NR sister gave rise to taxable dividend | 110 |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | a s. 247(12) secondary-adjustment deemed dividend paid by Canco to an LLC sister qualified under Art. IV(6) for the 5% Treaty-reduced rate on dividends to its U.S. parent | 498 |
4 April 2019 Internal T.I. 2017-0736531I7 - Articles IV(6) and X(6) of the Canada-US Treaty
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| Tax Topics - Treaties - Income Tax Conventions - Article 4 | Art. IV(6) of Cda-US Treaty can be satisfied where Canadian branch profits are earned at bottom of stacked LLCs held by qualifying persons | 247 |
7 September 2016 External T.I. 2014-0563781E5 - Articles 10 and 11 of Canada-UK Treaty
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| Tax Topics - Treaties - Income Tax Conventions - Article 11 | limited partners of an LP can deal at arm’s length with a Canadian subsidiary of the LP | 452 |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | limited partners of an LP could deal at arm’s length with a Canadian sub of the LP | 222 |
28 May 2015 IFA Roundtable Q. 12, 2015-0581521C6 - IFA 2015 Q.12: Canada-Switzerland Treaty
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| Tax Topics - Treaties | resolution of conflicting French and English Treaty versions of Swiss Treaty in taxpayer's favour | 89 |
28 May 2015 IFA Roundtable Q. 2, 2015-0581551C6 - IFA 2015 Q.2: GAAR and treaty shopping
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | treaty shopping | 99 |
11 July 2014 External T.I. 2013-0497381E5 - REIT investment in a US IRA.
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| Tax Topics - Treaties - Income Tax Conventions - Article 22 | REIT income distributions to IRA at 15% | 222 |
31 May 2013 External T.I. 2013-0486011E5 - Loan to non-resident - Part XIII tax
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23 October 2012 External T.I. 2012-0440101E5 - Article X(6) Canada-US Treaty
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17 May 2012 IFA Roundtable, 2012-0444151C6 - Hybrid Partnerships and Branch Tax Liability
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| Tax Topics - Treaties - Income Tax Conventions - Article 29A | 170 |
2012 Ruling 2012-0435211R3 - Article XXIX-A(3) of the Canada-US Tax Convention
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| Tax Topics - Treaties - Income Tax Conventions - Article 29A | US Holdco in Chap. 11 receives dividend | 235 |
2012 Ruling 2011-0424211R3 - Article X(2) and 84(3) deemed dividends
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Income Tax Technical News No. 44 13 April 2011 [archived]
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|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | inter-provincial loss shifting | 65 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | exchangeable debenture appreciation not recognized | 90 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) | exchangeable debenture appreciation not recognized | 106 |
| Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) | exchangeable debenture exercise | 84 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | FMV basis in contributed property | 35 |
30 November 2010 Annual CTF Roundtable, 2010-0386391C6 - Branch Tax
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13 July 2009 External T.I. 2009-0318701E5 - Article X(2) and Tiered Partnerships
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21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6 - Meaning of beneficial owner in Article 10, 11 & 12
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| Tax Topics - Treaties - Income Tax Conventions - Article 11 | 84 |
2007 Ruling 2007-0248021R3 - Cdn Japan Convention: withholding rate deemed div.
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2004 IFA Roundtable Q. 3, 2004-007223 -
17 December 2002 External T.I. 2002-0155005 - FTC for U.K. Dividends
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30 January 2002 External T.I. 2001-0106695 - Subs. 219(5.3);Article X of Canada-US Treaty
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8 January 1996 External T.I. 9428025 - RETURN OF CAPITAL FROM A DELAWARE CORPORATION
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) | all distributions from Delaware corps are dividends | 92 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) | all distributions from Delaware corps are dividends | 92 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend | 92 |
4 March 1993 Memorandum (Tax Window, No. 30, p. 18, ¶2472)
October 1992 T.I. 921009 "Loans to Non-Residents"
3 September 1992 T.I. 920333 "Interest-Free Loans - Reason for Withholding"
8 April 1992 T.I. (913412 (March 1993 Access Letter, p. 83, ¶C180-135; Tax Window, No. 18, p. 10, ¶1847)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 28 |
Articles
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Elio Andrea Palmitessa, "Italian Supreme Court Applies the Beneficial Ownership Clause to Pure Holding Companies", Tax Notes International, April 17, 2017, p. 259
Timothy Hughes, Matias Milet, Marc Richardson-Arnould, "Private Equity Funds – Selected Canadian Tax Issues", Tax Management International Journal, 2016, p.84
Jack Bernstein, "Canada-US Tax Traps for LLCs", Canadian Tax Highlights, Volume 22, Number 2, February 2014, p. 11
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | 143 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 144 |