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GAIN- CANADA-IRELAND TAX AGREEMENT-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A resident of Ireland is subject to tax of 15% on the disposition of shares that are taxable Canadian property in light of Article VI of the Canada-Ireland Convention. ...

12 April 1995 External T.I. 9417135- CANADIAN MUTUAL FUND TRUST-NON-RESIDENT-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 The Canada-Germany Convention does not reduce the 25% withholding tax applicable to distributions by a Canadian mutual fund trust to a resident of Germany. ...

22 August 1995 External T.I. 9520405- TREATY ("RESIDENCE") STATUS OF A "S" CORPORATION-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Because an S corporation will be subject to tax in the U.S. on its world-wide income if certain conditions are not met, it is considered to be a resident of the U.S. for purposes of the Canada-U.S. Convention. ...

1 February 2002 External T.I. 2001-007820-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The exclusion in subparagraph 3(b) of Article XI of the Canada-Argentine Convention is applicable where the payor of the interest is not the final user of the purchased machinery. ...

28 December 2000 External T.I. 2000-0003915- Article XXVI A of Canada-US Tax Treaty-- summary under Article 26A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26A General discussion of Article XXVI A of the Canada-U.S. Convention. ...

(Tax Window, No. 3, p. 10, ¶1237)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. corporation may be considered to be carrying on business in Canada where it supplies to its Canadian subsidiary employees that are under its direct control and supervision, in which case the provision of space to the employees at the Canadian subsidiary may constitute a place of business for purposes of Article V of the Canada-U.S. Convention. ...

8 October 1992 T.I. 920970 (September 1993 Access Letter, p. 419, ¶C111-056)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Where a property drops in value after 1984 and then recovers before the date of its disposition, the availability of any transitional relief in paragraph 9 of Article XIII of the Canada-U.S. Convention should be discussed with the competent authority. The acquisition of a depreciable property on a partial (1/2 step-up basis) under former s. 70(5)(b) would be regarded as a non-recognition transaction for the purposes of paragraph 9. ...

(Tax Window, No. 18, p. 11, ¶1809)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The gain realized by a U.S. resident who sells an interest in a U.S. partnership which conducts a manufacturing business in Canada and does not own Canadian real estate, will not be taxable in Canada. ... Convention will not apply because the property sold is a partnership interest rather than the property used in the Canadian business. ...

(Tax Window, No. 8, p. 23, ¶1420)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Alimony or maintenance paid by a person who is a U.S. resident at the time of the payment will be considered to arise in the U.S. for purposes of paragraph 6 of Article XVIII of the Canada-U.S. Convention even if the payments were made pursuant to an order of a Canadian court made while the payer was a Canadian resident. ...

(Tax Window, No. 10, p. 22, ¶1500)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 The payment of the "minimum amount" under a RRIF to a U.S. ... Convention. However, where the annuitant requests a payment in excess of the minimum amount for the year, the excess payment will not qualify as a periodic pension payment or will be subject to withholding tax of 25% pursuant to s. 212(1)(q) of the Act. ...