It is no news, nor will it come as a shock to anyone that more companies are entering the global market, including small and medium-sized businesses. Deliberate expansion into a promising...
Posted by Elliot Kravitz, ATP on 06/06/2021
14.2.2[a] Independent Personal ServicesArticle XIV governs income earned by an individual from independent personal services. Any type of business or professional activity could qualify...
Posted by The Accounting and Tax on 01/21/2019
14.1 Introduction to Article XIV – Independent Personal ServicesArticle XIV deals with the provision of independent services in one Contracting State by an individual who is...
Posted by The Accounting and Tax on 12/06/2018
13.3.2 [a] Article XIII(1) – Gains from Real PropertyParagraph 1 authorizes the U.S. to tax gains derived by a resident of Canada from the alienation of real property situated...
Posted by The Accounting and Tax on 11/26/2018
13.2.2 [a] Article XIII(1) – Gains from Real PropertyArticle XIII(1) provides that the gains derived by a U.S. resident from the alienation of real property situated in Canada...
Posted by The Accounting and Tax on 10/30/2018
As the international tax planning & tax law raise in complexity, this could be tough to navigate international tax problems & several regulations that settle down by several...
Article XIII generally deals with the taxation of capital gains realized by residents of Canada or the U.S. that may be also taxed in the other State. The general rule dealing...
Posted by The Accounting and Tax on 10/06/2018
12.3.2[a] Article XII(1) – Residence – Based Jurisdiction to TaxParagraph 1 of Article XII stands for the proposition that a resident of a country receiving royalty income...
Posted by The Accounting and Tax on 10/06/2018
11.3.2[a] Article XI(1) – Residence – based Jurisdiction to TaxParagraph 1 of the Article preserves the right of a Contracting State to tax income earned by its residents,...
Posted by The Accounting and Tax on 06/25/2018