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 »