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Inome Tax Convention and Large Corporations Tax Unedited CRA Tags 181.1(3)(d), 181.4, Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XXIII Dear Sirs: Re: Canada- United States Income Tax Convention, 1980 (the "Convention") and the Proposed Large Corporations Tax This is in reply to your letter dated July 13, 1990. ... Article XXIII of the Convention applies in respect of the Proposed Large Corporations Tax. 2. ...

Réponse du ministère du Revenu Quelque soit l'engagement d'une convention fiscale au niveau du droit international, il est clairement reconnu que ces conventions ont force de loi au Canada à partir du moment où Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information elles sont adoptées par une législation interne appropriée. ... Par conséquent, chaque convention fiscale doit faire l'objet d'une législation distincte pour avoir force de loi au Canada. Notons en rapport avec ceci que le paragraphe 10(6) des Règles de 1971 concernant l'application de l'impôt sur le revenu précise que toute mention dans la Partie XIII de la Loi d'un taux supérieur au taux stipulé dans une convention fiscale est, à l'égard des paiements fait à un résident de cet autre pays, interprétée comme une mention du taux stipulé dans la convention fiscale. ...

Income Tax Convention JUNE 5, 1989 Appeals Branch Specialty Rulings Appeals & Referrals Division Directorate K.B. ... Income Tax Convention 8-0293 (1980) (the "Convention") Article XII Royalties on Motion This is in reply to your memorandum of May 1, 1989 wherein you are concerned about our position not to tax royalty payments in respect to videotapes of motion picture films under the Convention. Our views, which is based on the comments in paragraph 3 of Article XII of the Technical Explanation to the Convention which states "...copyright royalties and other like payments in respect of the production or reproduction from such works on videotape... for private (home) use... ...

Principal Issues: Does Article XVI of the US convention exempt earnings of a Canadian resident from tax in Canada? ... Convention (the "Convention"). As discussed with you, Article XVI of the Convention does not exempt earnings from entertaining of a Canadian resident from Canadian tax. ... This letter only addresses the result of the application of Article XVI of the Convention to your client and should not be construed as an acceptance by Revenue Canada that XXXXXXXXXX is self-employed. ...

7 April 1991 Income Tax Severed Letter- Whether an exempt charitable organization situate in Israel is “resident of a Contracting State” for purposes of Article IV of the Canada- Israel Income Tax Convention Unedited CRA Tags Canada-Israel Income Tax Convention Article IV XXX This is in reply to your letter of March 19, 1991 in which you questioned whether we would consider an exempt charitable organization situate in Israel to be "resident of a Contracting State" for purposes of Article IV of the Canada- Israel Income Tax Convention (the "Convention"). This will confirm that for the purposes of the Convention and other income tax treaties comparable thereto we are of the opinion that an exempt organization that is created or organized in a Contracting State will generally be considered to be a "resident of" that State notwithstanding that it is granted exemption from tax in such State by the tax laws thereof. Accordingly, an exempt charitable organization that is resident in Israel will be entitled to the benefit of Article XXI of the Convention (ie. reduced withholding rate of 15%) on income arising in Canada from an estate or trust. ...

7 May 1991 Income Tax Severed Letter- Canada-France Income Tax Convention Unedited CRA Tags Canada-France Income Tax Convention article XXIX Dear Sir: This is in response to your letter of April 17, 1991, and our various conversations with respect to the deduction for Canadian income tax purposes of XXX Our understanding of the limited information provided by you is summarized as follows: 1. ... XXX You asked whether pursuant to paragraph 5 of Article XXIX of the Canada-France Income Tax Convention (1975), (the "Convention") XXX would qualify as deductible amounts paid to a pension plan that is recognized as such for purposes of the Canadian Income Tax Act (the "Act"). ... In addition, as paragraph 5 was added to the Convention by the Protocol thereto which entered into forced on October 1, 1988 and will have effect on January 1, 1989, only contributions made during the period from January 1, 1989 to the day of termination of your employee status with XXX We regret that our response could not be more favourable. ...

Income Tax Convention] DATE JUN 2 1988. Audit Directorate International Audits Division Reorganizations and Non-Resident Division Foreign Section N.R. ... Income Tax Convention (the "Convention") This is in reply to your memorandum of March 10, 1988. At issue are the following words in paragraph 5 of Article XXV of the Convention: "...the capital of which is wholly or partly owned or controlled... ...

Income Tax Convention (1980)] DATE: February 20, 1986 TO-A DATE: PROVINCIAL AND INTERNATIONAL RELATIONS DIVISION FROM-DE HEAD OFFICE Assessing Division ATTENTION R. ... Income Tax Convention (1980) We are writing to request clarification of Article XIX of the Canada-United States Income Tax Convention (1980) as it applies to employees of the U.S. ... Article XIX of the 1980 Convention no longer includes a reference to "any agency" of the United States. ...

Income Tax Convention (1980) (the "Convention") on January 1, 1986, the interest paid on these advances would have been exempt pursuant to the paragraph 2 of Article XII of the former 1942 Canada-U.S. ... Issue Paragraph 3(e) of Article XI of the Convention provides an exemption for interest paid with respect to an obligation entered into before the date of the Convention (i.e. September 26, 1980), provided that such interest would have been exempt under Article XII of the 1942 Convention. ...

Raisons POUR POSITION ADOPTÉE: Les paiements sont exemptés en vertu de la convention fiscale Canada- France. / The payments are exempt by virtue of the dispositions of the Canada- France Tax Convention. ... Question Vous nous demandez si, dans la situation précitée, nous partageons votre interprétation de la Loi et de la Convention. ... Ces paiements seraient plutôt visés par l'article 7 de la Convention qui traite des bénéfices des entreprises. ...