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17 September 2007 External T.I. 2007-0250101E5- Article 12(4) of Canada/Switzerland Tax Convention Principal Issues: Whether an aircraft would be considered to be equipment for the purposes of Article 12(4) of the Canada-Switzerland Tax Convention. ... Zhang (613) 957-2104 September 17, 2007 Dear XXXXXXXXXX: Re: Article 12(4) of the Canada-Switzerland Tax Convention We are writing in response to your letter of August 16, 2007 in which you requested our comments regarding the tax treatment of payments for the use of an aircraft under the Canada-Switzerland Tax Convention (the "Treaty"). ...

Income Tax Convention on Canadian Tax and Filing Obligations Unedited CRA Tags 69(3), 150(1), 150(2), 115 24(1) 900414   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9245 August 30, 1990 Dear Sirs: Re:  Canadian Tax and Filing Obligations U.S.- Canada Tax Convention This is in reply to your letter dated March 20, 1990 to the Non-Resident Taxation Division.  ... In particular we note that the Commentary on the Model Double Taxation Convention on Income and Capital in the Report of the OECD Committee on Fiscal Affairs, 1977 is consistent with the view that USCo has a permanent establishment in Canada. ...

31 January 1990 Ruling HBW6591G1 F- Canada-Germany Income Tax Convention Unedited CRA Tags n/a 19(1) David R. Senécal   (613) 957-2074   HBW 6591-G1   HBW 4125-G1 January 31,1990 Mr. 19(1) Re:  Exchange of Information under the Canada-Germany Income Tax Convention (1956)  19(1) Following your request dated November 14, 1989, we have attempted to obtain the information required.  ...

5 February 1990 Internal T.I. 90M02427 F- Competent Authority Request under Canada-Finland Tax Convention Unedited CRA Tags n/a TELEX MESSAGE   Originator:  B. FIORAVANTI   Date:  5/02/90   Branch:  LEGISLATION   Building:  MACDONALD   Room Number:  1000   Telephone Number:  957-2073   Other Destination:  FINLAND      123241 FIMIN SFAttention: 19(1)     File No. 90M02427 Message: RE:  19(1) COMPETENT AUTHORITY REQUEST UNDER CANADA- FINLAND TAX CONVENTION OUR INTERNATIONAL AUDITS DIVISION HAS WRITTEN TO YOU ON APRIL 14, 1988, AND FURTHER ON NOVEMBER 2, 1988, AND JUNE 1, 1989. ...

ACC 8675 F- Canada-France Income Tax Convention on Pensions Unedited CRA Tags n/a   September 28, 1989 S. ... Senécal   957-2074      HBW 4125-F1 19(1) Paragraph 5 Article XXIX  Canada-France Income Tax Convention As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada.  ...

12 October 1989 Income Tax Severed Letter ACC8587 F- Canada-France Tax Convention Unedited CRA Tags n/a   October 12, 1989 S. ... Pettifer 957-2072      HBW 4125-F1 24(1) PARAGRAPH 5, ARTICLE XXIX CANADA-FRANCE INCOME TAX CONVENTION As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada. ...

16 June 1991 External T.I. 9113055 F- Canada-Italy Income Tax Convention Unedited CRA Tags 2(1), 126(1), 126(7) non-business income tax, Treaty Italy 5-911305 Dear Sirs: Re:  Canada-Italy Income Tax Convention This is in reply to your letter of May 7, 1991 wherein you requested our views on the income tax liabilities of a Canadian resident in the following hypothetical situation as outlined in your letter. ... X is employed in Italy by an employer that does not have a permanent establishment (within the meaning of Article V of the Canada-Italy Income Tax Convention Act,1980 (the "Tax Treaty") or other fixed base in Canada. 3.      ...

27 July 1990 Ruling 901351 F- Canada-Australia Income Tax Convention on Capital Gains Unedited CRA Tags n/a   July 27, 1990 International Audits Division Rulings Directorate   G. ... Calderwood (613) 957-2126 Director   901351     SUBJECT:  24(1) Canada-Australia Income Tax Convention This is in reply to your Memorandum dated June 18, 1990 whereby you requested our opinion as to whether residents of Australia are exempt from Canadian tax liability in respect of capital gains realized on the disposition of taxable Canadian property, particularly shares in the capital stock of a corporation resident in Canada (other than a public corporation), by virtue of the Canada-Australia Income Tax Convention (1980) (the "Treaty"). ...

Income Tax Convention Unedited CRA Tags n/a 24(1) 900875   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9246 August 30, 1990 Dear Sirs: Re:  Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your reply to your letter dated May 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

7 October 2010 External T.I. 2009-0344201E5- Canada-US Tax Convention Unedited CRA Tags Articles IV(7)(b), XXI, XXIX A Canada-US Tax Convention Principal Issues: Is a US charitable organization eligible for the exemption from Canadian withholding tax provided in Article XXI of the Convention in respect of an item of income received from a Canadian-resident ULC that is fiscally transparent under the laws of the US? ... Kauffman Attention: XXXXXXXXXX October 7, 2010 Dear Sirs: Re: Canada-United States Tax Convention This is in reply to your correspondence of September 21, 2009. ... Tax Convention (the "Treaty"). The income of the US LP is allocated to the Limited Partner and General Partner in proportion to their partnership interests. 3) US LP owns all of the issued and outstanding shares and debt of a Nova Scotia Unlimited Liability Company ("Canco"). ...