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(Tax Window, No. 31, p. 4, ¶2510)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Tax-exempt entities are resident in the jurisdiction in which they are organized. ...

3 September 1992 T.I. 920333 "Interest-Free Loans- Reason for Withholding"-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 The word dividend in the Canada U.S. ...

(Tax Window, No. 15, p. 14, ¶1679)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Re taxability of rental payments derived from the use of moveable property in Canada by a Norwegian limited partnership. ...

Convention. ...

(Tax Window, No. 1, p. 9, ¶1166)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Because the taxpayer's activities in Canada must be considered in relation to its business activities elsewhere, a U.S. resident will not be precluded from being considered to have a permanent establishment in Canada by virtue only of the Canadian activities having no expectation of profit. ...

(Tax Window, No. 32, p. 6, ¶2598)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A sales force in Canada could be regarded as stable or permanent activities of a U.S. corporation in Canada. ...

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Re taxation of a U.S. charitable organization's share of dividends received by a U.S. partnership from a Canadian resident corporation. ...

(February 1990 Access Letter, ¶1124)-- summary under Section 255 Summary Under Tax Topics- Income Tax Act- Section 255 Neither section 255 of the Act, nor section 5 of the Income Tax Conventions Interpretation Act, are relevant to the interpretation of the "in Canada" requirement in s. 127(9). ...

No. 2, p. 4, ¶1047)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 In the case of a corporation incorporated in Canada and having its place of effective management in The Netherlands, Canada will not agree that the corporation is a resident of The Netherlands in the absence of evidence that Canadian tax is not being avoided. ...

T.I. 921585 (December 1992 Access Letter, p. 24, ¶C111-048)-- summary under Article 19 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 19 A Canadian citizen who is employed at the Canadian embassy in Washington will be subject to tax in Canada even after he has acquired U.S. citizenship. ...