OrbitaxTreaty between Canada and UK – Tax Court of Canada decides that individual resident in Canada and the United Kingdom, but not liable to UK tax, is subject to tax in Canada
|Treaty Development|Canada; United Kingdom
The Applicant, Conrad Black, made an application for the determination of a question of law under section 58 of the Tax Court of Canada Rules (General Procedure) prior to the hearing of his case. (a) Issue. The issue was:
| - | whether or not article 4(2) of the Canada - United Kingdom Income Tax Treaty (1978) (the Treaty), which deemed Black (according to t… |
