Article 29A - Limitation on Benefits

Administrative Policy

8 September 2017 External T.I. 2014-0549771E5 - Article XXIX-A:3

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) a trust is related to a sub of its corporate trustee 72
Tax Topics - Treaties - Income Tax Conventions - Article 3 "person related thereto" defined by ITA meaning of "related person" 37

5 November 2015 Internal T.I. 2013-0496401I7 - XXIX-A(3) - Active Trade or Business Exception

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2 December 2014 CTF Roundtable, Q. 7

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Factor

(US vs. CAN)

Situation A

Situation B

Situation C

Situation D

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2014 Ruling 2013-0511761R3 - Cross-border financing Canada - USA

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22 May 2014 May IFA Roundtable, 2014-0526711C6 - Article XXIX-A(3) of the US Treaty

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26 November 2013 CTF Roundtable, 2013-0507961C6 - Article XXIX-A LOB provisions

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2013 Ruling 2012-0471921R3 - Deemed dividend on return of capital

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 4 PUC increase and distribution 356

28 November 2010 Annual CTF Roundtable, 2010-0387001C6 - Canada-US Treaty LOB - Treatment of Interest

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17 May 2012 IFA Roundtable, 2012-0444151C6 - Hybrid Partnerships and Branch Tax Liability

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2012 Ruling 2012-0435211R3 - Article XXIX-A(3) of the Canada-US Tax Convention

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2012 Ruling 2012-0458361R3 - Cross-Border Financing

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 4 derivative benefit re loan interest 273

28 June 2010 External T.I. 2009-0329511E5 - United States - Dividend Withholding Rate

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12 April 2010 External T.I. 2009-0317941E5 - Canada-US Tax Convention - Article XXIX A

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8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6 - Qualifying person & multiple shares

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28 May 2009 Internal T.I. 2009-0319161I7 - Canada-US Treaty - Article XXIX A(3)

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Income Tax Technical News No. 41, 23 December 2009 under "5th Protocol to the Canada-US Tax Convention – Limitation on Benefits," Q. 4 - Example.

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17 July 2008 IFA Roundtable, 2008-0272361C6 - Limitation of Benefits

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Articles

Steve Suarez, "Canada to Unilaterally Override Tax Treaties with Proposed New Anti-Treaty-Shopping Rule", Tax Notes International, 3 March 2014, 797-806.

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Koichiro Yoshimura, "Clarifying the Meaning of 'Beneficial Owner' in Tax Treaties", Tax Notes International, November 25, 2013, p. 761.

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Angela W. Y. Yu, Grace W. Loh, "Ambiguity in the U.S.-Canada Treaty's Publicly-Traded Test Should Be Resolved in Favor of Canadian Dual-Class Public Companies", Tax Management International Journal, 2011, p. 589

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Elinore J. Richardson, Stephanie Wong, "Cross-Border Financing Into Canada More Difficult Under Canada's New LLB Provision", Corporate Finance, Vol. XVI, No. 1, 2009, p. 1734

Vern Krishna, "Limitation on Treaty Benefits: Part One", Canadian Current Tax, Vol. 20, No. 1, October, 2009, p. 1.

Edward Miller, "Potential Limitations of the Limitation on Benefits Clause in the Fifth Protocol to the Canada-U.S. Income Tax Convention", International Tax, CCH, December 2007, No. 37, p. 4.

Finance

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