Article

Deemed U.S. Corporation not a U.S. Treaty Resident: HRMC v. GE Financial Investments Ltd.

April 3, 2025
Social Media
Download
Download
Read Mode
Subscribe
Summarize

Article 4(1) of Canada’s income tax treaties defines a “resident” of a Contracting State to mean a person who is subject to comprehensive tax in that State “by reason of” various criteria, such as domicile, residence, place of management or any other criterion of a similar nature. What does “by reason of” mean? Does it mean that the criteria are necessary conditions of residency, or does it mean merely that the criteria are examples of conditions that could give rise to comprehensive tax?

In an article entitled, Deemed U.S. Corporation not a U.S. Treaty Resident: HRMC v. GE Financial Investments Ltd., Jared Mackey discusses a recent decision of the Court of Appeals for England which explores this issue. The article is published by the Federated Press International Tax Planning journal (Volume XXVIX, No. 1) and can be accessed on Taxnet Pro by Thomson Reuters.

Social Media
Download
Download
Subscribe
Republishing Requests

For permission to republish this or any other publication, contact Amrita Kochhar at kochhara@bennettjones.com.

For informational purposes only

This publication provides an overview of legal trends and updates for informational purposes only. For personalized legal advice, please contact the authors.

Latest Insights

See All Insights
Navigating the World of Online Canadian Sweepstakes
Blog

Navigating the World of Online Canadian Sweepstakes: Legal Pitfalls and the Role of AI

October 6, 2025
Benjamin K. ReingoldStephen D. Burns
Benjamin K. Reingold & Stephen D. Burns
New Legislative Proposals Boost the Appeal of Employee Ownership Trusts
Blog

New Legislative Proposals Boost the Appeal of Employee Ownership Trusts

October 3, 2025
Wesley R. NovotnyWade RitchieZachary Thacker
Wesley R. Novotny, Wade Ritchie & Zachary Thacker
Placeholder
Article

Bennett Jones on Tax Disputes: September 2025

October 1, 2025
Edwin G. Kroft KCAntoine MesservierAndrew Young
Edwin G. Kroft KC, Antoine Messervier & Andrew Young