Words and Phrases - "month"

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21 November 2023 Internal T.I. 2021-0880101I7 - Article 5(3)(b) of the Canada-Mexico Treaty

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 5
the “six months” test in Art. 5(3)(b) of the Mexico Treaty should be day-counted (more than 183 days)

Art. 5(3)(b) of the Mexico-Canada Convention provides that a “permanent establishment” includes:

(b) the furnishing of services, including...

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Words and Phrases
month

23 November 2023 Internal T.I. 2020-0850381I7 - Article V(4) of the Canada-U.S. Treaty

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 5
the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time

Art. V(4) of the Canada-U.S. Treaty provides that a permanent establishment exists in a Contracting State if the use of an installation or...

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Words and Phrases
month use standby charge

MNR v. Kayelle Management (Yukon) Inc., 94 DTC 6116, [1994] 1 CTC 271 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 157 - Subsection 157(1)

The taxpayer, which was a Canadian-controlled private corporation, had a fiscal year-end of February 1, 1990. It was not required to pay the final...

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Words and Phrases
month
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 28 46