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  Société Générale v. R. - FCA: Article XX(2) of Canada-Brazil Treaty gives tax credit on net income, not gross

  Feb 09, 2017 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: Here the taxpayer was arguing that the specific language of the “tax sparing provision” found in Article XXII(2) of the Canada-Brazil Tax Convention provided a tax credit in Canada on the amount of the gross bond interest taxable in Brazil, not the next interest actually taxed in Canada. The Tax Court ruled that the credit only applied to the net income subject to tax in Canada. The Federal Court of Appeal dismissed the appeal from the bench with costs to the Crown both in the Court of Appeal and the Tax Court.
  Société Générale v. R. - FCA: Article XX(2) of Canada-Brazil Treaty gives tax credit on net income, not grossREAD MORE »
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  Société générale v. R. - TCC: Interpretation of Article XXII(2) of the Canada-Brazil Tax Treaty

  Aug 18, 2016 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: Articles XXII(2) and (3) of the Canada-Brazil Tax Treaty provide that Canada must provide a tax credit for interest earned by a Canadian resident in Brazil ... In this pre-trial motion the Tax Court was essentially asked to determine a narrow point of law: is the credit determined on the basis of gross interest income or net interest income?
  Société générale v. R. - TCC: Interpretation of Article XXII(2) of the Canada-Brazil Tax TreatyREAD MORE »