Article 29

Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion

CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction

plan recognized as a pension plan under Art. 29(5) of the Cda-France Convention cannot be an EBP

agreement with CASD terminated when S Corp. ceased to be fiscally transparent

Canadian royalties received exempt of U.K. tax by non-dom U.K. resident not eligible for Treaty-reduced rate

Treaty does not fetter the right of the US to impose GILTI tax with reference to Canadian subs’ income

Cdn competent authority agreement with S-Corp. extends to income of a qualified subchapter S Corp. subsidiary thereof

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)

Treaty residence not domestically applicable