Cases
Wolf v. Canada, 2002 DTC 6853, 2002 FCA 96
The taxpayer, a U.S.-resident mechanical engineer was hired by a Canadian corporation ("Kirk-Mayer") so that his services could be provided to a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 | 125 | |
| Tax Topics - Treaties - Income Tax Conventions | 62 |
Canada v. Dudney, 2000 DTC 6169 (FCA)
The taxpayer (a U.S. resident) provided his services, as independent contractor, to a nonresident corporation which, in turn, was hired by a...
See Also
Dudney v. The Queen, 99 DTC 147, [1999] 1 CTC 2267 (TCC), aff'd supra.
The taxpayer, who was an engineer resident in the United States, was hired by a U.S. corporation ("OSG") to provide services to a Canadian oil and...
Hinkley v. MNR, 91 DTC 1336, [1991] 2 CTC 2778 (TCC)
The taxpayer, who was a U.K.-resident structural engineer, was hired by a Canadian-resident employment agency to work for a period of some months...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Treaties | 19 |
Administrative Policy
16 June 2014 Internal T.I. 2014-0527901I7 - Public Lending Right Payments under Art. 14
Payments made by the Canada Council under the public lending rights program, i.e., payments to Canadian authors in order to compensate them for...
18 June 2013 Internal T.I. 2011-0393451I7 - Treaty Exemption - Fixed Base available in Canada
A non-resident of Canada who was resident in Ireland for purposes of the Canada-Ireland Treaty, worked as an independent contractor, under a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | Dudney folowed | 156 |
2 January 2003 Internal T.I. 2002-0162287 - Fixed base in Canada
Although the non-resident taxpayer came to Canada on a recurring basis to perform the same or similar business activities (in respect of...
IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"
Where an individual is present in Canada for a period not exceeding 60 days and is not entering Canada on a recurring basis, the individual will...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary or Wages | 20 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 5 | 42 |
23 July 1991 Memorandum (Tax Window, No. 7, p. 15, ΒΆ1368)
By virtue of paragraph 1 of Article XIII of the Canada-Barbados Convention, the maximum withholding tax which Barbados may impose on management...
86 C.R. - Q.82
administrative policy re requests for reduced withholding based on Article XVII(2) of the U.S. Convention.