CRA on Withholding Tax on Interest Payments and s. 212(13.2) Deemed Residents

In 2014-0521831R3, the CRA comments on the application of subsection 212(13.2) of the Income Tax Act (Canada) and Article XI of the Canada-US Tax Treaty, in the context of Part XIII withholding tax on interest payments made by the non-resident (who is deemed resident for particular purposes under s. 212(13.2) of the Income Tax Act (Canada)) to a US resident.

Prepared by: Asif Abdulla

Asif Abdulla is a partner working out of the Vancouver office of Thorsteinssons LLP. He practices in the area of domestic and international tax planning for individuals, trusts, corporations and other private enterprises with a view to achieving tax efficiency… more »