CRA Tax Treaties Links - T1 and more

Tax Topics
1

Income Tax Folio S5-F2-C1, Foreign Tax Credit

Interpretation Bulletin IT-506, Foreign Income Taxes as a Deduction from Income (archived)

T2209 Federal Foreign Tax Credit
https://www.canada.ca/en/revenue-agency/services/forms-publications/forms/t2209.html

T2036 Provincial or Territorial Foreign Tax Credit
https://www.canada.ca/en/revenue-agency/services/forms-publications/forms/t2036.html

CPP and Foreign Pensions Benefits Overview

CRA Tax Treaty - list of topics and links.

Check with CRA for updates as to which CRA processing units in which locations deals with your Tax Treaty and Foreign Income matters. This changes frequently to balance workloads and competencies.
Summary of list of Canada’s Tax Treaties with citations by country.
https://www.fin.gc.ca/treaties-conventions/cndtxtreat_-eng.asp
This section offers information on Canada’s tax conventions with other countries. - https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/tax-treaties.html

" Canada has tax conventions or agreements – commonly known as tax treaties – with many countries. The main purposes of tax treaties are to avoid double taxation and to prevent tax evasion.

Tax treaties:

  • Define which taxes are covered and who is a resident and eligible to the benefits.
  • Often reduce the amounts of tax to be withheld from interest, dividends, and royalties paid by a resident of one country to residents of the other country.
  • Limit tax of one country on business income of a resident of the other country to that income from a permanent establishment in the first country.
  • Define circumstances in which income of individuals resident in one country will be taxed in the other country, including salary, self-employment, pension, and other income.
  • May provide for exemption of certain types of organizations or individuals.
  • Provide procedural frameworks for enforcement and dispute resolution."

Applies

Finance Canada - Status and texts of tax treaties

CRA - Competent Tax Authority - agreements and notices with respect to specific provisions in the tax treaties.

Competent Tax Authority Services

OECD - Exchange of tax information

Mutual Agreement Procedure (MAP)

Certificate of Tax Residency
This certificate is issued by the country in which you reside and regularly report and remit taxes. This is certificate is the document which establishes your tax treaty benefits and applicable laws, statutes, and regulations. It is issued annually upon written or phoned in request. You need a country to country specific version.

Statement of joint cooperation regarding abusive tax transactions

Guidance for taxpayers requesting tax treaty relief for cross-border pension contributions.

Enhanced financial account information reporting

Tax Information Exchange Agreements (TIEAs) - list by county

Convention on mutual administrative assistance in tax matters. Original convention signed by Canada in 2004. Protocol signed in 2011. Ratified agreement in 2013. Agreement in force in Canada effective 2014-03-01. Falls under the tax acts - Income Tax Act, Excise Tax Act, and Excise Tax Act, 2001.

Social security agreement - Service Canada
Pensions overview - lived or living outside Canada - pensions and benefits overview.

Exempt foreign income - T1 Line 256
https://www.canada.ca/en/revenue-agency/services/tax/individuals/topics/about-your-tax-return/tax-return/completing-a-tax-return/deductions-credits-expenses/line-256-additional-deductions/line-256-exempt-foreign-income.html

Line 256 - Exempt foreign income
If you reported foreign income on your return (such as support payments you received from a resident of another country and reported on line 128) that is tax-free in Canada because of a tax treaty, you can claim a deduction for it. If you do not know if any part of the foreign income is tax-free, contact the CRA.

Under the Canada-United States tax treaty, you can claim a deduction equal to 15% of the U.S. Social Security benefits, including U.S. Medicare premiums which you reported as income on line 115.

If you have been a resident of Canada and have received U.S. Social Security benefits continuously during the period starting before January 1, 1996, and ending in 2017, you can claim a deduction equal to 50% of the U.S. Social Security benefits received in 2017.

This 50% deduction also applies to you if you are receiving benefits related to a deceased person and you meet all the following conditions:

The deceased person was your spouse or common-law partner immediately before their death.
The deceased person had, continuously during a period starting before 1996 and ending immediately before their death, been a resident of Canada and received benefits to which paragraph 5 of Article XVIII of the Canada-United States tax treaty applied.
You have, continuously during a period starting at the person’s time of death and ending in 2017, been a resident of Canada and received such benefits.