23 July 1986 Income Tax Severed Letter

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.

Ms Robin Jackson Department of Communications Room 348 300 Slater Street Ottawa, Ontario K1A OC8

D.B. Morphy 957-2100

JUL 23 1986

Dear Ms Jackson:

Enclosed as requested, are photocopies of Articles XV, XVI, XVII and XXX of the Canada - US Income Tax Convention (1980) and of the related technical explanations. This Convention (the 1980 Convention) provides separate rules for compensation received by entertainers and athletes in Article XVI. Under the previous Convention (the 1942 Convention) tax on compensation for personal services, including those provided by entertainers, was governed by the provisions of Article VII, a copy of which is also enclosed.

The 1980 Convention became law during 1984 and the particular provisions contained in Article XV, XVI and XVII came into force on January 1, 1985, pursuant to paragraph 2(b) of Article XXX. Pursuant to paragraph 5 of Article XXX, however, if the provisions of the 1942 Convention were more favourable than those to which paragraph 2(b) applied, the 1942 Convention continued to apply for 1985. The net result was that the new rules came into effect on January 1, 1986, in respect of the compensation paid to entertainers and athletes.

We hope this will be helpful to you.

Yours truly,

for Director Small business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch

Enclosures