Article 14 - Independent Personal Services

Cases

Wolf v. Canada, 2002 DTC 6853, 2002 FCA 96

The taxpayer, a U.S.-resident mechanical engineer was hired by a Canadian corporation ("Kirk-Mayer") so that his services could be provided to a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Canada v. Dudney, 2000 DTC 6169 (FCA)

The taxpayer (a U.S. resident) provided his services, as independent contractor, to a nonresident corporation which, in turn, was hired by a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

See Also

Dudney v. The Queen, 99 DTC 147, [1999] 1 CTC 2267 (TCC), aff'd supra.

The taxpayer, who was an engineer resident in the United States, was hired by a U.S. corporation ("OSG") to provide services to a Canadian oil and...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Hinkley v. MNR, 91 DTC 1336, [1991] 2 CTC 2778 (TCC)

The taxpayer, who was a U.K.-resident structural engineer, was hired by a Canadian-resident employment agency to work for a period of some months...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Treaties 19

Administrative Policy

16 June 2014 Internal T.I. 2014-0527901I7 - Public Lending Right Payments under Art. 14

Payments made by the Canada Council under the public lending rights program, i.e., payments to Canadian authors in order to compensate them for...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

18 June 2013 Internal T.I. 2011-0393451I7 - Treaty Exemption - Fixed Base available in Canada

A non-resident of Canada who was resident in Ireland for purposes of the Canada-Ireland Treaty, worked as an independent contractor, under a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 5 Dudney folowed 156

2 January 2003 Internal T.I. 2002-0162287 - Fixed base in Canada

Although the non-resident taxpayer came to Canada on a recurring basis to perform the same or similar business activities (in respect of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"

Where an individual is present in Canada for a period not exceeding 60 days and is not entering Canada on a recurring basis, the individual will...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

23 July 1991 Memorandum (Tax Window, No. 7, p. 15, ΒΆ1368)

By virtue of paragraph 1 of Article XIII of the Canada-Barbados Convention, the maximum withholding tax which Barbados may impose on management...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

86 C.R. - Q.82

administrative policy re requests for reduced withholding based on Article XVII(2) of the U.S. Convention.

Articles

Lee, "Rent-a-Professional Arrangement Takes Advantage of Treaty Protection", Taxation of Executive Compensation and Retirement, December/January 1992, p. 536.

Navigation