Article 26

See Also

Assistant Director of Income Tax-I, New Delhi v. M/s E-Funds IT Solution Inc., Civil Appeal No. 6082 of 2015, 24 October 2017, (2018), 13 SCC 294

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Tax Topics - Treaties - Income Tax Conventions - Article 5 provision of ancillary services rather than direct customer services does not engage a services PE 459

Alberta Printed Circuits Ltd. v. The Queen, 2011 DTC 1177 [at 967], 2011 TCC 232

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

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax amount paid in error not a tax 131
Tax Topics - Treaties - Income Tax Conventions - Article 24 overpayment of U.S. tax not U.S. tax 148

Administrative Policy

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel IV: Selected Topics in Transfer Pricing

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3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority

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15 September 2020 IFA Roundtable, Q.4

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) no extension under Bill-20 (re COVID) beyond December 31, 2020 47

15 September 2020 IFA Roundtable, Q.3

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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(b) ss. 247(2)(b) and 245(2) treated the same for MAP procedure purposes 177

16 May 2018 IFA Roundtable Q. 1, 2018-0748181C6 - New U.S. GILTI Tax

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Tax Topics - Treaties - Income Tax Conventions - Article 29 Treaty does not fetter the right of the US to impose GILTI tax with reference to Canadian subs’ income 186

13 June 2017 STEP Roundtable Q. 8, 2017-0693381C6 - Single-member disregarded U.S. LLC

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Tax Topics - Treaties - Income Tax Conventions - Article 29 single member LLC with dual resident member could elect to be C-Corp and S-Corp, and then consider applying for relief under Art. 29(5) 158
Tax Topics - Income Tax Act - Section 125 - Subsection 125(1) 20(12) deduction where LLC with U.S.-source income and single Canadian-resident member - or FTC if U.S. sources of income 182

86 C.R. - Q.38

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80 C.R. - Q.6

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Articles

Martin Marcone, "Resolution Procedures for Intergovernmental Transfer Pricing Disputes: Part 2", 23 Can. Current Tax", Volume 23, Number 12, September 2013:

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Richard G. Tremblay, "Canada-U.S. Treaty Fifth Protocol: Binding Arbitration", Canadian Current Tax, Vol. 18, No. 11, p. 1, August 2008

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Calderwood, "The Competent Authority Function: A Perspective from Revenue Canada", 1989 Conference Report, c. 39

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