Article 8

Cases

Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221

Article 5 of the Canada-U.K. Income Tax Convention of 1946 did not exempt earnings of a U.K.-resident shipping company derived from managing or...

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See Also

Director of Income Tax v. A.P. Moller Maersk, Civil Appeal No. 2960 of 2017 (Supreme Court Of India, Civil Appellate Jurisdiction)

A Danish international shipping company (“Maersk”) charged local agents in India, who booked and tracked cargo, for their pro rata share of...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 12 computer tracking-system charges of a Danish company to local agents were profits of its international shipping business rather than for technical services 346

Administrative Policy

11 April 2023 Internal T.I. 2023-0964101I7 - Tax issues for cross-border employees

Regarding the deductibility of a contribution made to a 401(k) plan by a cross-border employee (with a hybrid work arrangement) who exercises a...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 24 FICA contributions of a cross-border employee are deductible only re employment income from duties physically performed in the US 243
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) employment income does not arise in the U.S. for Treaty purposes to the extent the duties are performed in a Canadian home office 140

23 October 2012 External T.I. 2011-0431301E5 - Meaning of Substantial Operation

CRA was asked whether an operation that provides temporary services, for a period of less than six months, constitutes a "substantial operation"...

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14 February 2012 External T.I. 2011-0428531E5 - Art. VIII, 6 Canada-US Tax Convention

the 183-day test in Art. VIII, para. 6 of the Canada-US Convention is applied on an item-buy-item basis (e.g., for a particular boxcar).

28 April 2008 External T.I. 2007-0238071E5 F - Voiturier public

The taxpayer uses the services of subcontractors to have the goods transported, but handles all other aspects of the business and remains...

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Words and Phrases
common carrier

31 October 1991 T.I. (Tax Window, No. 12, p. 17, ¶1559)

Where a taxable Canadian corporation leases a ship on a bare boat basis from a corporation resident and managed in the Netherlands, Part XIII tax...

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