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TREATY-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 "As long as the amount of the pension arising in the U.S. would have been excluded from taxable income in the U.S. by a U.S. resident recipient, such amount would be exempt from taxation in Canada by a Canadian resident recipient. ... -Canada] Convention...." A taxpayer who receives a periodic pension from the International Monetary Fund should file a letter from the IMF annually with his or her T1 return. ...

PENSION RECEIVED BY CANADIAN (4093-U5-100-18)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 In order for RC to grant treaty-exemption for the portion of U.S. pension benefits paid to a Canadian resident that represent a return of premiums, it will require a breakdown from the plan. ... Convention. ...

1 March 1995 External T.I. 9426805- WITHHOLDING TAX ON INTEREST (HAA 4093 U5-100-11)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The exemption in the post-1994 version of paragraph 3(d) of Article XI of the Canada-U.S. Convention would apply to exempt interest paid by a Canadian resident on a U.S. dollar credit card issued by a Canadian financial institution where that institution had agreed with a U.S. bank that the U.S. bank would reimburse U.S. merchants for purchases made by the customer in the U.S.; the Canadian financial institution assigned to the U.S. bank all receivables due to it arising from such use of the card; and the cardholders made all payments with respect to their account balances directly to the U.S. bank. ...

10 March 1995 External T.I. 9506415- CAPITAL GAINS- CANADA-AUSTRALIA TREATY (HAA-4093-A3-100)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Where a corporation which is resident in Australia realizes a gain on the disposition of shares of a corporation resident in Canada, the phrase "items of income" in paragraph 1 of Article XXI of the Canada-Australia Convention will include such gain even if it is realized on capital account rather than income account. ...

8 January 1996 External T.I. 9428025- RETURN OF CAPITAL FROM A DELAWARE CORPORATION-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Because the purpose of the "source country deemed dividend rule" in the definition of "dividend" in paragraph 3 of Article X of the Canada-U.S. Convention is only "to ensure that the source country's right to tax an amount that would not otherwise meet the definition of a 'dividend', but is treated as such in the source country, will be governed by paragraph 2 of Article X", that rule does not trammel the ability of Canada to tax as a dividend a distribution received by Canadian-resident shareholders of a Delaware corporation that might not be treated like a dividend under the U.S. ...

2 January 1996 External T.I. 9514185- ARTICLE XIII CANADA-ISRAEL TREATY-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Where a corporation resident in Israel alienates shares of a corporation resident in Canada the only assets of which are shares of a second Canadian corporation, paragraph 3 of Article XIII of the Canada-Israel Income Tax Convention generally will not be applicable, and by virtue of paragraph 4 of that Article, the Israeli corporation will not be liable to taxation in Canada on the gain notwithstanding that the property of the second Canadian corporation consists principally of immovable property situated in Canada. ...

5 November 2012 Internal T.I. 2012-0462151I7- Foreign Tax Credits-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Canco held portfolio investments in shares of U.S. companies in connection with funding its insurance liabilities. ... Income Tax Convention, a portion of the income from Canco’s Canadian XX business must be re-sourced to the U.S. for the purposes of section 126 of the Act. ... CRA went on to find that, given that gains or losses on the shares were not subject to Canadian income tax by virtue of the Convention, they were deemed by s. 126(6)(c) to be a separate source for purposes of s. 126. ...

23 October 2012 External T.I. 2011-0431301E5- Meaning of Substantial Operation-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 CRA was asked whether an operation that provides temporary services, for a period of less than six months, constitutes a "substantial operation" for purposes of Art. 8, para. 2 of the Canada-Sweden Convention. ... The CRA has previously expressed its views on the factors considered in determining whether an active trade or business is "substantial" for the purposes of Article XXIX-A(3) of the Canada-United States Tax Convention. ...

16 June 2014 External T.I. 2013-0515431E5- International traffic and airline enterprise-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 U.K company's provision of crew to Canadian airline/Reg. 102 withholding or waiver notwithstanding Treaty exemption During peak season, Canco, which transports passengers to destinations inside and outside Canada, is supplied planes and non-resident pilots and crew by an arm's length U.K. resident ("Forco") to transport Canco's passengers. ... Convention as well as being effectively managed and controlled there, and does not have a permanent establishment in Canada. ... Convention, pursuant to Art. 3, para. 2, it has the meaning provided in s. 248(1), and that provided the principal purpose of the voyage is to transport passengers on such a flight, the employment duties of Forco's crew members are exercised aboard an aircraft operated in international traffic, so that the U.K. is given the right under Art. 15, para. 3 to tax them on their remuneration from employment exercised on such flights. ...

2012 Ruling 2011-0430761R3- Paid-up capital Increase-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 two-step distribution with S-Corp shareholder Canco1 is a Canadian-resident unlimited liability company which is a wholly-owned subsidiary of Parentco, which is a qualifying person for purposes of the Canada-US Income Tax Convention and has elected to be taxed in accordance with subchapter S of Chapter 1 of the Code. ... IV, para. 7(b) of the Convention will not apply. ...