12.3.1 U.S. Taxation of Outbound Royalty Payments 12.3.1[a] Definition of RoyaltiesThe Code generally defines the term “royalty” by enumerating the kinds of property...
11.3 Explanation & Interpretation of Article XI under U.S. Law 11.3.1 U.S Domestic Taxation of Interest Paid to Canadian Residents11.3.1[a] Definition of InterestInterest...
6.3.1 Taxation of Investments in U.S Real Property by Canadian Investors6.3.1 (a) - IntroductionThere are many tax and legal considerations that must be weighed before making an investment...
5.3.1[a] U.S. Taxation of Foreign PersonsThe U.S. tax treatment of foreign persons and foreign-related transactions depends primarily on three criteria:1 – Whether the income earned...