U.S.-Canada income tax treaty requires income of U.S. branch to be determined under facts and circumstances.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on November 1, 1997. The length of the article is 753 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Tax benefits may be possible for corporations whose situations are similar to those of the taxpayer in North West Life Assurance Co. of Canada, decided by the Tax Court in 1996. The court held that IRC section 842(b) was not applicable because it was inconsistent with parts of the US-Canada income tax treaty which requires a facts and circumstances approach to the taxation of Canadian corporations' US branches' income. The income is best determined by looking at separate accounts of branches.

Citation Details
Title: U.S.-Canada income tax treaty requires income of U.S. branch to be determined under facts and circumstances.
Author: Diane L. Renfroe
Publication:The Tax Adviser (Magazine/Journal)
Date: November 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n11 Page: 690(2)

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