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 »