Words and Phrases - "standby charge"

a
83
b
44
c
75
d
50
e
37
f
31
g
18
h
13
i
72
j
2
k
2
l
30
m
53
n
25
o
38
p
79
q
3
r
75
s
88
t
46
u
14
v
8
w
22
y
2
“
1

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