Generally, Article VII provides that the business profits of a person resident in one Contracting State should not be taxable in the other Contracting State unless the particular...
Posted by The Accounting and Tax on 08/31/2017
IntroductionThis article of the treaty talks about following points:1 – The business profits of a resident of a Contracting State shall be taxable only in the State unless the...
Posted by The Accounting and Tax on 08/31/2017
6.3.1 Taxation of Investments in U.S Real Property by Canadian Investors6.3.1 (a) - IntroductionThere are many tax and legal considerations that must be weighed before making an investment...
Posted by The Accounting and Tax on 07/28/2016
6.1 IntroductionArticle VI (Income from Real Property) affirms the jurisdictional powers of the source State to impose its income tax on income derived by the resident of the residence...
5.3.1[a] U.S. Taxation of Foreign PersonsThe U.S. tax treatment of foreign persons and foreign-related transactions depends primarily on three criteria:1 – Whether the income earned...
5.2.1[a] Taxation of Income of Non-Residents GenerallyA non-resident person is subject to Part I tax in Canada if the non-resident, at any time in a taxation year,1 – Was employed...
Posted by The Accounting and Tax on 06/21/2016
5.2.2[a] Article V(1) – Definition of Permanent EstablishmentArticle V (1) provides a general concept of the notion of “permanent establishment” for the purposes of the Treaty.For...
Article IV(3)A situation of dual Resident Corporation may arise if a corporation is considered a resident in the U.S. under the treaty by virtue of its incorporation in the U.S.,...
4.3.1 (a) Residence of IndividualsUnder U.S domestic tax law, all individuals are subject to U.S tax, unless specifically exempted.U.S citizens are subject to U.S. tax on a worldwide...