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...
7.2.2 [a] Article Vii[1]Business Profits – Taxation of Profits Attributable to a permanent EstablishmentBusiness profits of a U.S. resident carrying on a business in Canada are...
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...
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...