See Also
Cheek v. The Queen (2002), docket 1999-1113-IT-G (TCC)
In finding that the taxpayer, who was a U.S. resident who provided radio commentary for each Blue Jays game, was not an artiste or athlete for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions | 47 |
Khabibulin v. The Queen, 00 DTC 1426 (TCC)
Article 12 of the Canada-USSR treaty provided an exemption from Canadian income tax in respect of the personal activities of a USSR athlete...
Administrative Policy
14 July 2022 Internal T.I. 2020-0869441I7 - Article XVI(4) of Canada-US Treaty
A U.S.-resident professional athlete signed a multi-year contract with a Canadian sports team which, in addition to salary, provided for the...
27 July 2016 External T.I. 2015-0603271E5 - Subsection 216.1(1) and permanent establishment
A U.S.-resident actor provides Canadian acting services through an LLC or S corp. The 23% withholding tax under ITA s. 212(5.1) on the gross...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 216.1 - Subsection 216.1(1) | late filing under s. 216.1 not accommodated | 216 |
| 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 |
1 March 2010 Internal T.I. 2009-0346951I7 F - Article XVI-Établissement stable-Province
A U.S.-incorporated resident of the U.S. for Treaty purposes (“Non-Resident Corporation”), whose shares were 50% owned by a non-resident...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) | being on concert tour in Canada did not render the various arenas fixed places of business, given lack of “regularity and recurrence” | 140 |
| Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) - Paragraph 400(2)(e) | using massive stage equipment for Canadian concerts did not result in deemed PEs given that at each venue under 30 days and in Canada under 90 days | 240 |
16 September 2009 External T.I. 2008-0295951E5 F - Article XVI de la Convention Canada-É.U
By virtue of paragraph 1 of Article XVI of the Convention, an American artist or athlete ("Non-resident") has, in your opinion, no tax payable in...
11 December 2002 External T.I. 2002-0146465 F - Article XVI Canada-E.U.
Regarding income earned by a US-resident athlete from Canadian activities through an “S Corp.”, CCRA referred to the provisions of Art. XVI of...
15 July 1992 T.I. 920480 (January - February 1993 Access Letter, p. 9 ¶C9-253)
An association of professional racing car teams is not a league "with regularly scheduled games" for purposes of paragraph 3(a) of Article XVI of...