Article 16

See Also

Cheek v. The Queen (2002), docket 1999-1113-IT-G (TCC)

In finding that the taxpayer, who was a U.S. resident who provided radio commentary for each Blue Jays game, was not an artiste or athlete for...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions 47

Khabibulin v. The Queen, 00 DTC 1426 (TCC)

Article 12 of the Canada-USSR treaty provided an exemption from Canadian income tax in respect of the personal activities of a USSR athlete...

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Administrative Policy

14 July 2022 Internal T.I. 2020-0869441I7 - Article XVI(4) of Canada-US Treaty

A U.S.-resident professional athlete signed a multi-year contract with a Canadian sports team which, in addition to salary, provided for the...

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27 July 2016 External T.I. 2015-0603271E5 - Subsection 216.1(1) and permanent establishment

A U.S.-resident actor provides Canadian acting services through an LLC or S corp. The 23% withholding tax under ITA s. 212(5.1) on the gross...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 216.1 - Subsection 216.1(1) late filing under s. 216.1 not accommodated 216
Tax Topics - Income Tax Act - Section 115 - Subsection 115(2.1) prohibition against acting income being filed on a net basis in absence of timely s. 216.1 election 105

1 March 2010 Internal T.I. 2009-0346951I7 F - Article XVI-Établissement stable-Province

A U.S.-incorporated resident of the U.S. for Treaty purposes (“Non-Resident Corporation”), whose shares were 50% owned by a non-resident...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) being on concert tour in Canada did not render the various arenas fixed places of business, given lack of “regularity and recurrence” 140
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) - Paragraph 400(2)(e) using massive stage equipment for Canadian concerts did not result in deemed PEs given that at each venue under 30 days and in Canada under 90 days 240

16 September 2009 External T.I. 2008-0295951E5 F - Article XVI de la Convention Canada-É.U

By virtue of paragraph 1 of Article XVI of the Convention, an American artist or athlete ("Non-resident") has, in your opinion, no tax payable in...

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11 December 2002 External T.I. 2002-0146465 F - Article XVI Canada-E.U.

Regarding income earned by a US-resident athlete from Canadian activities through an “S Corp.”, CCRA referred to the provisions of Art. XVI of...

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15 July 1992 T.I. 920480 (January - February 1993 Access Letter, p. 9 ¶C9-253)

An association of professional racing car teams is not a league "with regularly scheduled games" for purposes of paragraph 3(a) of Article XVI of...

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