Article 4

PUC increase and distribution from a Canadian qualified REIT subsidiary of a US REIT so as to skirt Art. IV(7)(b) of the Canada-US Treaty

Art. IV(7)(a) of Canada-US Treaty not engaged where US-owned partnerships receiving royalties were transparent for US purposes

2-step distribution by a ULC to avoid Art. IV(7)(b) of the Canada-US Convention

reference to 2-step approach to avoiding IV(7)(a) anti-hybrid rule in Canada-US treaty

the place of effective management of trusts for treaty tie-breaker purposes was in the UK even though their CMC might be in Mauritius

a US LLC was not a resident of the US for purposes of the US-Ireland treaty

a Barbados IBC was a resident of Barbados for general treaty purposes

application of Canada-US treaty to a Canadian corporation that is a deemed U.S. resident under the anti-inversion rules

deemed US residence of UK corporation under US stapling rules did not cause residence for Treaty purposes

Treaty benefits could be created for a s. 216 structure by creating partnerships for US purposes