Article 14

Cases

Wolf v. Canada, 2002 DTC 6853, 2002 FCA 96

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Canada v. Dudney, 2000 DTC 6169 (FCA)

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See Also

Dudney v. The Queen, 99 DTC 147 (TCC), aff'd supra.

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Hinkley v. MNR, 91 DTC 1336 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Treaties 15

Administrative Policy

16 June 2014 Internal T.I. 2014-0527901I7 - Public Lending Right Payments under Art. 14

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18 June 2013 Internal T.I. 2011-0393451I7 - Treaty Exemption - Fixed Base available in Canada

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 5 Dudney folowed 144

2 January 2003 Internal T.I. 2002-016228 -

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IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"

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23 July 1991 Memorandum (Tax Window, No. 7, p. 15, ΒΆ1368)

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86 C.R. - Q.82

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Articles

Lee, "Rent-a-Professional Arrangement Takes Advantage of Treaty Protection", Taxation of Executive Compensation and Retirement, December/January 1992, p. 536.

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