Cases
Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221
Article 5 of the Canada-U.K. Income Tax Convention of 1946 did not exempt earnings of a U.K.-resident shipping company derived from managing or...
See Also
Director of Income Tax v. A.P. Moller Maersk, Civil Appeal No. 2960 of 2017 (Supreme Court Of India, Civil Appellate Jurisdiction)
A Danish international shipping company (“Maersk”) charged local agents in India, who booked and tracked cargo, for their pro rata share of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 12 | computer tracking-system charges of a Danish company to local agents were profits of its international shipping business rather than for technical services | 346 |
Administrative Policy
11 April 2023 Internal T.I. 2023-0964101I7 - Tax issues for cross-border employees
Regarding the deductibility of a contribution made to a 401(k) plan by a cross-border employee (with a hybrid work arrangement) who exercises a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 24 | FICA contributions of a cross-border employee are deductible only re employment income from duties physically performed in the US | 243 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | employment income does not arise in the U.S. for Treaty purposes to the extent the duties are performed in a Canadian home office | 140 |
23 October 2012 External T.I. 2011-0431301E5 - Meaning of Substantial Operation
CRA was asked whether an operation that provides temporary services, for a period of less than six months, constitutes a "substantial operation"...
14 February 2012 External T.I. 2011-0428531E5 - Art. VIII, 6 Canada-US Tax Convention
the 183-day test in Art. VIII, para. 6 of the Canada-US Convention is applied on an item-buy-item basis (e.g., for a particular boxcar).
28 April 2008 External T.I. 2007-0238071E5 F - Voiturier public
The taxpayer uses the services of subcontractors to have the goods transported, but handles all other aspects of the business and remains...
31 October 1991 T.I. (Tax Window, No. 12, p. 17, ¶1559)
Where a taxable Canadian corporation leases a ship on a bare boat basis from a corporation resident and managed in the Netherlands, Part XIII tax...