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
13.2.1 Canadian Taxation of Gains of Non-ResidentsCanada does not impose tax on gains from the disposition of property by a non-resident other than the disposition of taxable Canadian...
Posted by The Accounting and Tax on 10/22/2018
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...
Posted by The Accounting and Tax on 07/19/2016
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...
Posted by The Accounting and Tax on 06/21/2016
