Cases
Gulfmark offshore N.S. Limited v. Canada, 2007 DTC 5563, 2007 FCA 302
The taxpayer, a U.K. company, supplied a ship and a crew (obtained under subcontract from a related non-resident company) to a Canadian company...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 7 | 89 |
Administrative Policy
12 July 1991 Memorandum (Tax Window, No. 6, p. 3, ¶1352)
General discussion.
Rules
Administrative Policy
29 July 1994 External T.I. 9411695 - DEEMED DIVIDEND ON REDEMPTION CANADA-U.K. TREATY
Re application of paragraph 4 of Article 27 of the Canada-U.K. Convention where a share of a U.K. corporation held by a resident of Canada is...
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|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 29 | 103 |
20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)
A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to...
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|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 29 | 92 |
22 July 1991 T.I. (Tax Window, No. 7, p. 22, ¶1364)
Paragraph 2 of Article XXVII of the Canada-U.K. Convention not only restricts the right of taxpayers to claim total exemptions under the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 29 | 38 |