12 December 1989 Income Tax Severed Letter ACC8822 - Canada-U.S. Income Tax Convention on CPP and OAS

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

19(1)                         B. Fioravanti
                                             613-957-2073
                                             HBW 4125-U3
                                             HBW 4125-U3-1

December 12, 1989

Dear 19(1)

In reply to your letter of November 23, we confirm that benefits received under the Canada Pension Plan and the Old Age Security Act are "benefits under the social security legislation" of Canada within the meaning of paragraph 5 of Article XVIII of the Canada-United States Income Tax Convention. As a result, where such benefits are paid to a resident of the United States, they are not taxed by Canada. The Convention provides that one-half of such benefits will be exempt from tax in the United States. The other half will be taxable in the United States.

We trust that this will be of assistance.

Yours sincerely,

A/Director Provincial and International Relations Division