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In our view 24(1) Remuneration in respect or services rendered in connection with any trade or business carried on by the government of Canada in Belgium would be excluded from the application of paragraph I of Article XIX of the treaty by paragraph 2 thereof. ...

Thornley (613) 957-2101 February 23, 1990 Dear Sirs: Re: Non Profit Organizations ("NPO's") This is in reply to your letter of December 7, 1989 requesting our interpretation of a number of issues which have come to your attention in connection with NPO's. ...

XXXXXXXXXX Section 122.3 of the Income Tax Act (the "Act") provides that where an individual is an employee of a specified employer while working outside Canada for a period exceeding six consecutive months that commenced before the end of the year and performed all or substantially all the duties of employment outside Canada in connection with a contract under which the specified employer carried on business outside Canada with respect to qualified activities, such an individual is entitled to claim the OETC. ...

This exemption at source does not apply to royalties in respect of motion pictures, and of works on film, videotapes or other means of reproduction for use in connection with television broadcasting. ...

It is your understanding that the employees of an organization similar to yours have been granted an exemption from taxation on the employment income they receive in connection with the children under their care by reason of this provision. ...

Your view is that section 80 should be applied in same manor as discussed above for general partnerships and further, that section 80 will not be applied separately to the limited partners in connection with their release under the guarantees by the bank. ...

Kerwin of the Montreal District Office dated February 20, 1976 in connection with the XXX and this identical question of management fees (corporate charges). ...

These conditions are: 1) the nonresident must be dealing at arm's length with the corporation; 2) the interest must have been received in connection with an obligation where the evidence of indebtedness was issued by the corporation after June 25, 1975 end before 1983; 3) under the term of the obligation the corporation may not, under any circumstances, be obliged to pay more than 25% of try principal amount thereof within 5 years of the date of its issue except in the event of a failure or default under the said terms. ...

Where Canco has invested in a limited partnership, in order to retain its status as a limited partner, Canco could not, and would not be permitted to under the partnership agreements, take part in the control or management of the business of the partnerships or exercise any power in connection therewith, have any authority or power to act for the partnerships or hold itself out as having the power or authority to act for or bind the partnerships. ...

In connection with this situation, you have enclosed a document entitled "Terms of Agreement with Caregiver" (the Agreement) which indicates that the caregiver is an employee of the Association and that the Agreement ceases upon termination of funding by the Ministry. ...