Article 25

Table of Contents

Article 25 - Non-Discrimination
Cases(1)
See Also(7)
Administrative Policy(3)
Articles(2)

Cases

Sun Life Assurance Co. of Canada v. Pearson, [1984] BTC 223 (HC), aff'd [1986] BTC 282 (C.A.)

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See Also

Commissioner of Taxation v Addy, [2020] FCAFC 135

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Addy v Commissioner of Taxation, [2019] FCA 1768, rev'd [2020] FCAFC 135

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) 20-month non-“itinerant” stay under working visa based at a Sydney Australia home was residence 209

Kenny v. The Queen, 2018 TCC 2 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.94 foreign government assistance scuppered the “substantially all” test in s. 118.94 302

CIT v. Herbalife International India Pvt. Ltd, ITA 7/2007, 13 May 2016 (Delhi High Court)

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Hillis v. Canada (Attorney General), 2015 FC 1082

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. regard to object rather than political statements 55
Tax Topics - Treaties - Income Tax Conventions - Article 26A Art. 26 of US Convention did not prohibit FATCA information exchanges 174
Tax Topics - Treaties - Income Tax Conventions - Article 27 FATCA information exchanged automatically irrespective of any substantive U.S. tax liability was "relevant" to U.S. tax administration 387

Saipem UK Limited v. The Queen, 2011 DTC 1053 [at 297], 2011 TCC 25, aff'd 2011 DTC 5148 [at 6159], 2011 FCA 243

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Ramada Ontario Ltd. v. The Queen, 94 DTC 1071 (TCC)

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Administrative Policy

25 May 2017 External T.I. 2017-0685651E5 - Non-capital losses of LLC

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17 May 2010 External T.I. 2009-0346011E5 F - Immeuble - Convention Canada - Portugal

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Principal Residence - Paragraph (a) Portuguese home of Canadian resident could qualify for the principal residence exemption 57

24 October 1991 T.I. (Tax Window, No. 11, p. 7, ¶1531)

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Articles

Hugh J. Ault, "Some Reflections on the OECD and the Sources of International Tax Principles", Tax Notes International, 17 June, 2013, p. 1195

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Lewin, Wilkie, "Non-Discrimination Rules and International Taxation", Cahiers de droit Fiscal International, Volume LXXVIIIb, p. 357.

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