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Paragraph 3(d) of Article XI of the Convention, as it read prior to the Third Protocol, was worded as follows: "the interest is beneficially owned by a seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length;" (underlining for emphasis) Paragraph 3(d) of Article XI of the Convention was amended by the Third Protocol and currently reads as follows: "the interest is beneficially owned by a resident of the other Contracting State and is paid with respect to indebtedness arising as a consequence of the sale on credit by a resident of that other State of any equipment, merchandise or services except where the sale or indebtedness was between related persons;" (underlining for emphasis) The Technical Explanation to the Third Protocol, as it pertains to paragraph 3(d) of Article XI of the Convention, reads, in part, as follows: "...... ...

De plus, l'employé n'a pas droit au montant supplémentaire de 1 500 $ prévu à 60j.1)(ii)(B) à l'égard des années de service rachetées. ...

Reasons FOR POSITION TAKEN: Consistent with previously published positions (file # 9609563 and E9M19190). ...

In Young, a Tax Court of Canada case (86 DTC 1567), the Court considered the income tax consequences of a taxpayer who was awarded damages by Court Order in the following amounts: $10,000.00 for wrongful dismissal $12,500.00 for exemplary damages $12,500.00 for mental distress $ 5,000.00 for costs The taxpayer Appellant did not include the damages for mental distress and the exemplary damages in computing his income. ...

The value of the investments has increased considerably since they were acquired and now represents more than 50 % of the fair market value (FMV) of all of OPCO II's assets. ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office ("TSO") of the Canada Customs & Revenue Agency (the "CCRA"). ...

Principal Issues: Whether transportation and board & lodging allowances received from an employer for employment at a special work site or remote work location is taxable when the employee chooses to return daily to the principal place of residence. ...

Le paragraphe 206(2) de la Loi prévoit que si, à la fin d'un mois, le total des montants représentant chacun le coût indiqué d'un bien étranger dépasse de 30 % le coût indiqué de tous les biens détenus à ce moment, le contribuable visé à l'article 205 de la Loi doit payer un impôt égal à 1% du moindre de l'excédent ou du total des montants représentant le coût indiqué de tous les biens étrangers qu'elle a acquis après le 18 juin 1971. ...

You can find more information in our brochure, "P148, Your Appeal Rights Under the Income Tax Act ", which you can obtain from our web site at http://www.ccra-adrc.gc.ca/E/pub/tg/p148eq/README.html. ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"). ...