Article 2

Cases

Beame v. Canada, 2004 DTC 6103, 2004 FCA 51

Article VI of the Canada-Ireland Convention, which provided that "the rate of Canadian tax on income ... derived from sources within Canada by a...

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See Also

Niemeijer v. The Queen, 2010 DTC 1029 [at at 2677], 2009 TCC 624 (Informal Procedure)

Little, J. accepted the submission of the Crown that social security charges do not qualify as taxes. Accordingly, health insurance premiums paid...

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Administrative Policy

2 September 2025 External T.I. 2022-0945251E5 - Application of subsection 126(7)

CRA also found that the ยง4999 tax did not qualify as a tax covered by Art. II(2)(b) of the Canada-U.S. Income Tax Convention, so that Canada was...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax the US excise tax on parachute payments is not an income tax 176

26 March 2001 External T.I. 2001-0070165 F - Conventions fiscales et lois provinciales

Where a Quebec resident who was resident in a treaty country under the tie-breaker rule was otherwise subject to both Quebec tax and Part XIII tax...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 12 Canada will not reduce its withholding rate to 0% to make room for Quebec taxes imposed on the same property income 197

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