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13 December 1989 Income Tax Severed Letter ACC8814 F- Convention fiscale le 13 décembre 1989 Monsieur, Conformément au paragraphe 3 de l'article XXIV de la convention fiscale entre nos deux pays signée le 22 décembre 1975, nous souhaitons clarifier les modalités d'application de cette convention 24(1) A cet égard, nous vous proposons d'arrêter une position commune visant à déterminer les conséquences fiscales applicables dans les 24(1) Cette interprétation des dispositions de la convention s'appliquera aux encaissements réalisés à compter du 1 janvier 1988. ...

8 May 1990 Income Tax Severed Letter ACC9115- Canada-Switzerland Income Tax Convention 19(1) HBW 4125-S2 David R. Senécal (613) 957-2074 May 8, 1990 Dear 19(1) Pursuant to paragraph 4 of Article XXIV of the Canada-Switzerland Income Tax Convention signed by our two countries on August 20, 1976, we would like to clarify the application of the said Convention to the taxation of remuneration paid by a political subdivision of a Contracting State to an individual in respect of services rendered to that subdivision. Paragraph 1 of Article XIX of the Convention provides that such remuneration shall be taxable only in the State of source. ...

17 August 1988 Income Tax Severed Letter 5-5698 F- [Convention de Retraite] F. ... Aux fins de la partie I et XI.3 de la Loi de l'impôt sur le revenu (la "Loi"), cet arrangement constitue-t-il une convention de retraite? ... Selon nous, ce montant ne provient pas d'une convention de retraite tel que mentionné au dit alinéa. ...

7 March 1991 Income Tax Severed Letter- Canada-Switzerland Income Tax Convention Unedited CRA Tags 212, Canada-Switzerland Income Tax Convention Dear Sirs: Re: Canada-Switzerland Income Tax Convention (1976) (the "Convention") This is in reply to your letter dated December 17, 1990 whereby you request our opinion concerning the taxation of amounts paid by an estate of an individual who at the time of death was resident in Canada to XXX You have not provided sufficient information to permit us to express a conclusive opinion in respect of the matter raised by your letter. ... Paragraph 7 of Article X of the Convention will likely also apply in respect of amounts paid by an estate resident in Canada to a beneficiary resident in Switzerland. If paragraph 7 of Article X of the Convention is applicable the rate of Canadian income tax exigible under paragraph 212(1)(c) of the Act will be reduced from 25% to 15%, irrespective of the source of the estate's income (i.e. paragraph 7 of Article X does not only apply in respect of distributions made by an estate related to dividends received by the estate). ...

12 April 2010 External T.I. 2009-0317941E5- Canada-US Tax Convention- Article XXIX A Unedited CRA Tags Canada- US Tax Convention Articles XXIX A(2)(e), (3) and (4)(b) Principal Issues: (1) In applying the "base erosion" test in Article XXIX A(2)(e) or (4)(b), how will the CRA interpret the reference to payments made "indirectly" to persons other than qualifying persons? ... Question 1 In applying the "base erosion" test in Article XXIX A(2)(e) or (4)(b) Canada-United States Tax Convention, how will the CRA interpret the reference to payments made "indirectly" to persons other than qualifying persons? ... Response Article XXIX A(2)(e) of the Canada-United States Tax Convention (the "Treaty") provides as follows: 2. ...

Income Tax Convention Unedited CRA Tags 2(3), Art. 7 Canada/US Treaty 19(1) File No. 5-9189   R.C. ... Income Tax Convention (1980) (the "Convention") limits Canada's tight to tax a U.S. company to those situations where the company carries on business in Canada through a permanent establishment. ... We are enclosing a copy of the Convention and a T2 Corporation Income tax Guide for your perusal.  ...

Income Tax Convention in support of his request for the remission of the tax liability on the gain.     ... Income Tax Convention, and also, the foreign merger provisions of subsection 87(8) of the Canadian Income Tax Act. ... In the case of Article XIII(8) of the Convention, where a reorganization is afforded, tax free treatment in the taxpayer's country of residence, the competent authorities under the Convention may provide for deferral of tax under the laws of the other country in order to avoid double taxation. ...

Convention Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 13 923320 24(1) G. ... Income Tax Convention This letter is in reply to your fax dated November 5, 1992 in which you requested our views with respect to paragraph 7(b) of Article XIII of the Canada-U.K. ... Convention. 4. Office buildings (if not rental property or inventory) and the land under and/or adjacent thereto and necessary for the use thereof are Excluded Property. 5. ...

Income Tax Convention on Taxation of Estates 19(1) 5-9194 G. Arsenault (613) 957-2126 Dear Sir: Re: Article XXV of the Canada-U.S. Income Tax Convention, 1980 U.S. Estate Taxes This is in reply to your letter dated December 4, 1989. ... The US competent authority pursuant to Article XXVI of the Canada-United States Income Tax Convention, 1980 is: Mr. ...

Income Tax Convention (1980) (the "Convention") limits Canada's tight to tax a U.S. company to those situations where the company carries on business in Canada through a permanent establishment. Article V of the Convention defines a "permanent establishment" as a fixed place of business in Canada through which the business of a resident of the United States is wholly or partly carried on. ... We are enclosing a copy of the Convention and a T2 Corporation Income tax Guide for your perusal. ...