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Income Tax Convention, 1980 (the "Convention")] Revenue Canada Taxation Head Office XXXX T.B. ... Income Tax Convention, 1980 (the "Convention") This is in response to your letter dated October 24, 1988 in which you requested a technical interpretation of the above- referenced provisions of the Convention. ...

Income Tax Convention, 1980 (the "Convention")] T.B. Kuss (613) 957-2120 July 22, 1987 Dear Sirs: Re: Articles IV and XXI of the Canada-U.S. Income Tax Convention, 1980 (the "Convention") This is in reply to your letter of July 2, 1987 regarding the above- referenced subject. ...

25 March 1991 Income Tax Severed Letter 910104- [Article XIII(9) of the Canada-United States Income Tax Convention, 1980 (the "Convention")] Revenue Canada Taxation Head Office G. Arsenault (613) 957-2126 Attention XXXX Mar 25 1991 Dear Sirs: Re: Article XIII(9) of the Canada-United States Income Tax Convention, 1980 (the "Convention") This is in reply to your letter dated January 11, 1991 whereby you requested our views concerning whether a farm owned by a resident of the United States would constitute "an asset that on September 30, 1980 formed part of the business property of a permanent establishment situated in [Canada]" within the meaning of subparagraph (c) of paragraph 9 of Article XIII of the Convention. ... Paragraph 1 of Article V of the Convention expressly recognizes that a person may have a permanent establishment in a Contracting State where the business is only partly carried on. ...

Income Tax Convention (1980) (the “new treaty”) vs. Canada-U.S. Income Tax Convention (1942) (the “old treaty”) Unedited CRA Tags none This is in response to your memorandum of June 9, 1989. ...

29 April 2004 External T.I. 2003-0025221E5- Trusts under the Canada-US Convention Principal Issues: The application of the Canada-US convention to grantor trusts. ... The term "trust" is not defined in the Convention. Article 3 of the Income Tax Conventions Interpretation Act states: 3. ... X as a US resident for the purposes of the Convention may claim the benefits of both Articles X and XIII of the Convention. ...

17 November 2014 External T.I. 2014-0555061E5- Canada-Japan Income Tax Convention, Article 13 CRA Tags 115 248(1) "taxable Canadian property" Income Tax Convention Interpretation Act 6.3 Treaties XIII(4) Principal Issues: Meaning of expression "arising in the other Contracting State" Position: Gains from the disposition of TCP arise in Canada Reasons: See below XXXXXXXXXX Julia Belova 2014-055506 November 17, 2014 Re: Article 13 of the Canada-Japan Income Tax Convention We are writing in response to your email dated October 1, 2014 in which you enquired about the meaning of the expression "arising in the other Contracting State" in the context of paragraph 4 of Article 13 of the Canada-Japan Income Tax Convention (the "Treaty") (footnote 1). ... Pursuant to paragraph 6.3 of the Income Tax Convention Interpretation Act (Canada) (the "ITCIA"), except where a convention expressly otherwise provides, a gain from the disposition of TCP is deemed to arise in Canada. ... Yours truly, Olli Laurikainen, CPA, CA Section Manager For Division Director International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 "Convention Between The Government of Canada and The Government of Japan For The Avoidance of Double Taxation and The Prevention of Fiscal Evasion With Respect to Taxes on Income", signed on May 7, 1986, as amended by Second Protocol signed on February 19, 1999. 2 Income Tax Act (Canada), R.S.C. 1985, c.1 (5th Supp.), as amended to the date of this letter. ...

Reasons: Based on our interpretation of the Canada-Brazil Income Tax Convention and consistent with our positions in previous technical interpretations. ... OUR COMMENTS In our view, subparagraph V(2)(g) of the Convention is likely based on Article 5 of the 1963 OECD Model. ... Since the OECD Model and Commentaries, the Convention, the Income Tax Convention Interpretation Act and the Act do not define the expression "assembly project", it follows that the ordinary and common meaning of the words should prevail. ...

Dans votre lettre, vous demandez notre opinion concernant l'application du paragraphe 3 de l'Article XIII de la Convention entre le Canada et XXXXXXXXXX (la « Convention »). ... XXXXXXXXXX (le « Vendeur ») est une société résidente XXXXXXXXXX en vertu de la Convention. 2. XXXXXXXXXX (« Canco ») est une société résidente du Canada en vertu de la Convention. 3. ...

16 June 2014 External T.I. 2014-0516451E5- Application of Canada-Israel Tax Convention CRA Tags 250(4) Treaties Article III Small Business Venture Capital Act 3(1)(a) Principal Issues: Whether a B.C. Venture Capital Corporation qualifies as a Canadian resident company for the purposes of the Canada-Israel Tax Convention Position: Yes Reasons: A B.C. ... XXXXXXXXXX 2014-051645 Sylvain Grégoire June 16, 2014 Dear XXXXXXXXXX, Re: Application of Canada-Israel Tax Convention to BC Venture Capital Corporation This is in reply to your letter dated December 19, 2013 requesting our views as to whether a B.C. ...

Income Tax Convention and sections 116 and 245 of the Income Tax Act. ... Income Tax Convention and paragraph 2 of Interpretation Bulletin IT-173R2. ... Income Tax Convention (the "Convention") and sections 116 and 245 of the Income Tax Act (the "Act") to the situation hereinafter described. ...