liable to tax

19 August 2010 External T.I. 2009-0344111E5 F - Résidence Société Capital-Risque - Conv Can-France -- summary under Article 4

In finding that a French venture capital corporation ("VCC"), that was resident in France for French taxation purposes by virtue of its domicile as well as its effective place of management, and that had elected to be exempt from French corporate income tax respecting current income and capital gains on the sale of securities included in its portfolio, was a resident of France for purposes of the Canada-France Income Tax Convention, CRA stated:

By services, 28 November, 2015

Crown Forest Industries Ltd. v. Canada, 95 DTC 5389, [1995] 2 SCR 802, [1995] 2 CTC 64 -- summary under Article 4

Some of the income derived from a corporation incorporated in the Bahamas was effectively connected with the conduct by it of a business in the United States. However, Norsk paid no U.S. tax on barge rental payments received by it, including barge rental payments received from the Canadian taxpayer, by virtue of the exemption for international shipping companies contained in s. 883 of the U.S. Internal Revenue Code.

liable to tax