Article 16

See Also

Cheek v. The Queen (2002), docket 1999-1113-IT-G (TCC)

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Tax Topics - Treaties 47

Khabibulin v. The Queen, 00 DTC 1426 (TCC)

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Administrative Policy

27 July 2016 External T.I. 2015-0603271E5 - Subsection 216.1(1) and permanent establishment

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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

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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

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15 July 1992 T.I. 920480 (January - February 1993 Access Letter, p. 9 ¶C9-253)

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