Cases
Beame v. Canada, 2004 DTC 6103, 2004 FCA 51
Article VI of the Canada-Ireland Convention, which provided that "the rate of Canadian tax on income ... derived from sources within Canada by a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 3 | 117 |
See Also
Niemeijer v. The Queen, 2010 DTC 1029 [at at 2677], 2009 TCC 624 (Informal Procedure)
Little, J. accepted the submission of the Crown that social security charges do not qualify as taxes. Accordingly, health insurance premiums paid...
Administrative Policy
2 September 2025 External T.I. 2022-0945251E5 - Application of subsection 126(7)
CRA also found that the ยง4999 tax did not qualify as a tax covered by Art. II(2)(b) of the Canada-U.S. Income Tax Convention, so that Canada was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | the US excise tax on parachute payments is not an income tax | 176 |
26 March 2001 External T.I. 2001-0070165 F - Conventions fiscales et lois provinciales
Where a Quebec resident who was resident in a treaty country under the tie-breaker rule was otherwise subject to both Quebec tax and Part XIII tax...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 12 | Canada will not reduce its withholding rate to 0% to make room for Quebec taxes imposed on the same property income | 197 |