The Canadian tax system generally seeks to eliminate double tax in respect of dividends to Canadian individuals out of corporate income that was subject to either the “small business rate” or the “general rate” of corporate tax. This is achieved…
The CRA does not consider a US limited liability company (LLC) itself to be a resident of the US for purposes of benefits under the Canada-US tax treaty (Treaty). However, pursuant to Article IV(6) of the Treaty, the CRA will…
In 2012-0438691E5, the Canada Revenue Agency (CRA) considered a US corporation (US Co) that shipped inventory to an unaffiliated customer’s warehouse in Canada. Title to the inventory remained with US Co until such time as the customer required the…