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21 November 2023 Internal T.I. 2021-0880101I7 - Article 5(3)(b) of the Canada-Mexico Treaty -- summary under Article 5

Art. 5(3)(b) of the Mexico-Canada Convention provides that a “permanent establishment” includes:

(b) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than six months within any twelve month period

23 November 2023 Internal T.I. 2020-0850381I7 - Article V(4) of the Canada-U.S. Treaty -- summary under Article 5

Art. V(4) of the Canada-U.S. Treaty provides that a permanent establishment exists in a Contracting State if the use of an installation or drilling rig or ship in that State to explore for or exploit natural resources is for more than three months in any twelve-month period. The Directorate stated:

By services, 28 November, 2015

MNR v. Kayelle Management (Yukon) Inc., 94 DTC 6116, [1994] 1 CTC 271 (FCA) -- summary under Subsection 157(1)

The taxpayer, which was a Canadian-controlled private corporation, had a fiscal year-end of February 1, 1990. It was not required to pay the final instalment of its tax owing for that year until May 31, 1990 because this was the end of the third complete calendar month following its year-end). In finding that the due date instead was May 1, 1990, Décary J.A.

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