Martin v. The King, 2024 TCC 153 -- attach -- Article 15
US baseball players were taxable only on their income generated in playing in Canada
Article 15
24 February 2003 Internal T.I. 2002-0165537 F - Le détachement d'employés et l'article XV -- attach -- Article 15
exemption in Art. 15 of US Treaty unavailable where Canadian employee seconded to US affiliate, which reimburses for his payroll
9 July 2021 Internal T.I. 2021-0893981I7 - CERB received by non-residents -- attach -- Article 15
Other Income Art. accords Canada full right to tax CERB payments
Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021 -- attach -- Article 15
7 September 2016 External T.I. 2014-0559751E5 - Subsection 115(3) -- attach -- Article 15
comparison of Treaty and domestic method for pilot income on annual basis
20 July 2015 Internal T.I. 2012-0457671I7 - Treaty triangulation - Article 15 -- attach -- Article 15
treaty-exemption for remuneration of NR employee employed in deemed offshore drilling PE of employer resident in 2nd treaty county
25 January 2010 Internal T.I. 2009-0319951I7 - Article 15 & definition of permanent establishment -- attach -- Article 15
PE to be determined under treaty of residence of employee rather than employer
Article 15 - OECD
OECD Discussion Draft, Working Party 1 "OECD Model Tax Convention: Tax Treatment of Termination Payments," 25 June 2013: Recommended additions to...
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6 July 2012 Internal T.I. 2012-0440741I7 - stock option benefit derived by US resident -- attach -- Article 15
U.S. subs qualifies as payer of (therefore exempt) stock option benefit/domestic v. Treaty method
Luc de Broe, "Interpretation of Article 15(2)(b) of the OECD Model Convention: 'Remuneration paid by, or on Behalf of, an employer who is not a resident of the other state'", Bureau of International Fiscal Documentation, Vol. 54, No. 10, October 2000, p. 503. -- attach -- Article 15
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