Article 26A

Cases

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. regard to object rather than political statements 49
Tax Topics - Treaties - Income Tax Conventions - Article 25 FATCA requirements were reciprocal and were primarily imposed on financial institutions 166
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 361

Chua v. MNR, 2000 DTC 6527 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Retfalvi v. USA (2019), No. 18-2158 (U.S.C.A., 4th Circuit)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity creation of new collection right did not entail retrospectivity 159
Tax Topics - Statutory Interpretation - Revenue Rule pre-Treaty revenue rule 122
Tax Topics - Treaties Vienna convention approach applies to non-signatories 197
Tax Topics - Statutory Interpretation - Revenue Rule 116

Administrative Policy

25 July 2012 External T.I. 2011-0427221E5 - FBAR penalties

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 December 2000 External T.I. 2000-000391 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Wolfe D. Goodman, "When can the CCRA enforce a U.S. tax liability under Article XXVI-A of the Convention?", Goodman on Estate Planning, Vol. IX, no. 3, p. 716.

Navigation