The Resource Tax Court of Canada rules US LLC is treaty resident

Tax Court of Canada rules US LLC is treaty resident

Label
Tax Court of Canada rules US LLC is treaty resident
Title
Tax Court of Canada rules US LLC is treaty resident
Creator
Subject
Language
eng
Summary
On 8 April 2010, the Tax Court of Canada held that a US limited liability company (LLC) was liable to tax in, and therefore a resident of, the United States for purposes of the Canada-United States Income Tax Convention. The case overturns the long-established position of the Canada Revenue Agency that LLCs that are fiscally transparent for US tax purposes cannot be US residents for purposes of the treaty, a position that had greater relevance prior to the Fifth Protocol to the Treaty (which did not apply to the taxation years at issue)
Citation source
In: Tax planning international review. - London. - Vol. 37 (2010),
http://library.link/vocab/creatorName
Milet, M
Language note
English
http://library.link/vocab/subjectName
  • limited liability company
  • residence
  • tax treaty
  • case law
Label
Tax Court of Canada rules US LLC is treaty resident
Instantiates
Publication
Label
Tax Court of Canada rules US LLC is treaty resident
Publication

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