25 September 2012 B.C. CTF Roundtable Q. 10, 2012-0457591C6 - B.C. CTF 2012 - Q.10 US LLC -- summary under Article 4

As CRA is not in agreement with the decision in TD Securities (which, in any event, involved pre-5th Protocol timeframes). Accordingly:

Treaty benefits [under the Canada-U.S. Treaty as amended by the 5th Protocol] claimed by a fiscally transparent LLC with respect to an amount of income, profit or gain will be permitted only if the amount is considered to be derived, pursuant to Article IV(6), by a person who is a resident of the United States and that person is a "qualifying person" or is entitled, with respect to the amount, to the benefits of the Treaty pursuant to paragraph 3,4 or 6 of Article XXIX-A.

Topics and taglines
Topic
Treaties - Income Tax Conventions - Art. 4
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
326536
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
347249
Extra import data
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"field_roundtable_subquestion": "10",
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"field_legacy_header": "<a id=\"2012-0457591C6\"></a><a href=\"/?p=14498\">25 September 2012 B.C. CTF Round Table, Q. 10, 2012-0457591C6</a> (repeated in <a href=\"/?p=14501\">2012-0462881C6</a>) [LLC not entitled to Treaty benefits except under IV.6]"
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