Burton v Commissioner of Taxation, [2019] FCAFC 141 -- attach -- Article 24
“income” was the full U.S. gain, but FTC to be calculated based on Australian (1/2 recognition) principles
Article 24
6 July 2012 Internal T.I. 2012-0453461I7 F - rental losses Canada-France Treaty -- attach -- Article 24
s. 126(1) FTC re French income tax on rental income
Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141 -- attach -- Article 24
foreign tax credit was not required to be accorded to all the US tax on the gain
Satyam Computer Services Limited v Commissioner of Taxation, [2018] FCAFC 172 -- attach -- Article 24
a sourcing rule in the Australia-India Treaty imposed tax on a deemed royalty received by an Indian company
7 November 1994 External T.I. 9400965 - U.S. REAL PROPERTY INTEREST & FTC (5638-2) -- attach -- Article 24
FTC for U.S. FIRPTA tax payable on disposition of Canco shares as permitted by Art. XIII
Brian J. Arnold, "The Relationship between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties: A New Zealand Case", Bulletin for International Taxation July 2018, p. 430 -- attach -- Article 24
Canada- Israel Development Ltd. v. MNR, 85 DTC 718, [1985] 2 CTC 2460 (TCC) -- attach -- Article 24
taxes paid by a controlled foreign affiliate treated as tax paid by the Cdn shareholder
Commissioner of Inland Revenue v. Lin, [2018] NZCA 38 -- attach -- Article 24
Chinese tax spared on Chinese CFC income and attributed under CFC regime to New Zealand shareholder was not “in respect of” income derived by that shareholder from China
13 April 2017 External T.I. 2015-0601781E5 - U.S. tax paid in respect of an LLC's income -- attach -- Article 24
Canada's denial of foreign tax credits re undistributed LLC income is consistent with Art. 24 of Canada-US Treaty
Société Générale Valeurs Mobilières Inc. v. Canada, 2017 FCA 3 -- attach -- Article 24
a Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income
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