112 n c anadian tax journal revue fiscale canadienne

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Unformatted text preview: ements of this article.55 in addition to the tests in article xxix a(4)(a), article xxix a(4)(b) also requires the us company to meet the base-erosion test. The base-erosion test in article xxix a(4)(b) is identical to the base-erosion test in article xxix a(2)(e). ex ample 4: Interest Payments from C anadian Company to us oper ating Company This example relies on the same facts and assumptions as example 3, with the additional assumption that swissco is entitled to all of the benefits under the Canada-switzerland treaty.56 51 article xxix a(4)(a)(i) 52 article xxix a(4)(a)(ii). 53 article xxix a(4)(a)(iii). 54 see, for example, article 24(4)(a) of the Convention between the government of the united states of america and Luxembourg for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on income and Capital, signed at Luxembourg on april 3, 1996. The ultimate ownership rules generally have been interpreted as requiring that the ownership at the top individual level be tested. 55 This interpretation is supported by the example in the technical explana...
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This note was uploaded on 11/03/2013 for the course ACCOUNTING 346 taught by Professor William during the Fall '12 term at DeVry Chicago.

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