Article 24

Cases

Société Générale Valeurs Mobilières Inc. v. Canada, 2017 FCA 3

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See Also

Arsove v. The Queen, 2016 TCC 283 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) no credit for U.S. taxes which should have been imposed but were not 373

Société générale valeurs mobilières inc. v. The Queen, 2016 TCC 131, aff'd 2017 FCA 3

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Words and Phrases
appropriate attributable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) foreign source interest reduced by related expenses 390
Tax Topics - Treaties OECD commentaries applied to Brazil (not an OECD member) 209

Anson v. HMRC, [2015] UKSC 44

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation profits of LLC earned directly by members 36
Tax Topics - Treaties - Articles of Treaties - Article 3 scheme in Treaty article for allocating income between jurisdictions amounted to a definition of "source" 76
Tax Topics - Treaties - Articles of Treaties - Article 4 pragmatic approach to determining "same" - also appearing in IV,7(b) of Cda-US Treaty 130

HMRC v. Anson, [2013] EWCA Civ 63, rev'd supra

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation LLC not fiscally transparent 422

FLSmidth Ltd. v. The Queen, 2012 DTC 1052 [at 2745], 2012 TCC 3, aff'd 2013 DTC 5118 [at 6147], 2013 FCA 160

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Meyer v. The Queen, 2004 DTC 2393, 2004 TCC 199 (Informal Procedure)

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Administrative Policy

13 April 2017 External T.I. 2015-0601781E5 - U.S. tax paid in respect of an LLC's income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) Post-Anson, no credit for U.S. taxes paid by a Canadian member on undistributed LLC income 193

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 124
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax LLC tax paid by Cdn member not re business 163
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) only income was taxable capital gains 131
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) s. 20(14) deduction for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 418
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 316

[U.K] Revenue and Customs Brief 15 (2015): HMRC response to the Supreme Court decision in George Anson v HMRC (2015) UKSC 44 25 September 2015

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation Anson specific to its facts 104

23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) s. 40(3) gain had Cdn source/foreign tax not a "tax" if no refund sought 408
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax foreign tax not a "tax" if no refund sought 190

16 June 2014 Internal T.I. 2014-0525961I7 - ON Tax and Brazilian Tax Sparing

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Ontario - Taxation Act 2007 - Subsection 34(1) Brazilian tax-sparing rules operate independently of s. 126 so that they do not generate an Ontario FTC 217

13 January 2014 External T.I. 2013-0512581E5 - Sale of shares of Brazilian corporation

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10 June 2013 STEP CRA Roundtable, 2013-0480301C6 - 2013 STEP CRA Roundtable – Question 4

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5 November 2012 Internal T.I. 2012-0462151I7 - Foreign Tax Credits

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11 May 2012 External T.I. 2011-0428791E5 - Foreign Tax Credit

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15 March 2004 External T.I. 2003-002265 -

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20 February 2003 External T.I. 2002-014360 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) 158

20 February 2003 External T.I. 2002-0143605 -

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19 October 1998 Memo 8M18146

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3 March 1997 Memorandum 964132

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) 16

1995 Alberta CICA Round Table, Q. 13 (C.T.O. "U.S. Alternative Minimum Tax")

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Halifax Round Table, February 1994, Q. 5

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Articles

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

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Kevyn Nightingale, "The Net Investment Income Tax: How it applies to U.S. Citizens Abroad", International Tax, No. 73, December 2013, p. 9.

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Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(2) 0

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