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14 December 1990 Ruling HBW4125N1A F- Canada-Netherlands Income Tax Convention Unedited CRA Tags n/a 19(1) HBW 4125-N1   David R. ... In our view, the wording of paragraph 3 of Article 4 of the Canada-Netherlands Income Tax Convention has the same effect. ... Where agreement cannot be reached, the corporation will not be a resident of either State for most purposes of the Convention. ...

Income Tax Convention- Retirement Compensation Arrangement 19(1) 5-9190 D.S. ... Income Tax Convention (the "U.S. Convention") Retirement Compensation Arrangement ("RCA") This is in reply to your letter of November 30, 1989 requesting our views on the interpretation to be given to the terms "retirement plan" and "periodic pension payment" contained in Article XVIII of the U.S. ... Convention. It is our view that the rate of tax on the amounts paid to a U.S. resident in a situation such as that described above would be 25%. ...

Income Tax Convention Unedited CRA Tags 54(g), 250, 85, 116, 40(2)(b), Canada–U.S. ... Income Tax Convention (1980) (the Convention). You describe the facts as follows: 1. ... For purposes of the Convention, specifically paragraph 2 of Article IV thereof, Mr. ...

Income Tax Convention Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 5 Dear Sirs: Re: Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter dated September 14, 1990 whereby you asked the following questions concerning paragraph 3 of Article 5 of the Convention: 1. ... Paragraph 3 of Article 5 of the Convention must be interpreted by giving meaning to the words used therein. ... In our opinion, the phrase "shall not be deemed to include" in the introduction of paragraph 3 of Article 5 of the Convention is synonymous with "shall be deemed not to include". ...

7 October 1991 Income Tax Severed Letter- Meaning of \"International Traffic\" in Canada- Netherlands Income Tax Convention Unedited CRA Tags Canada- Netherlands Income Tax Convention Subject: Meaning of "International Traffic" in Canada- Netherlands Income Tax Convention, 1986 The term "international traffic" is defined by paragraph 1(g) of Article 3 and Paragraph II of the Protocol to the Convention. ... " In connection with the interpretation/definition of the term "international traffic" in the Canada-Netherlands Convention reference must also be made to Paragraph II of the Protocol. ... " Thus the definition of the term "international traffic" in the Canada-Netherlands Convention is in effect virtually the same as the definition in the Canada-United States Income Tax Convention, 1980. ...

Income Tax Convention on Employment Income 24(1) 5-9792 M.P. Sarazin (613) 957-2125 Dear Sirs: Re: Clause 115(2)(e)(i)(B) of the Income Tax Act (Canada) (the "Act") and the Canada-U.K. Tax Convention (the "Convention") This is in reply to your letter dated March 6, 1990 in which you requested our advice regarding the reporting requirements in the following situation. ... Facts 24(1) Your client has based his calculation of withholding tax upon the interaction of clause 115(2)(e)(i)(B) of the Act and paragraph of Article 15 of the Convention. ...

Position: The trust was a resident of the United States for the purposes of the Convention. ... Income Tax Convention (1980) (the "Convention"). 6. Canco, Opco and Otherco are corporations incorporated and resident in Canada. 7. ... It is unlikely in such case that the Convention would exempt such gain. ...

Tax Convention (the "Convention") and paragraph 254(a) of the Act. ... The particular provisions would be Article VIA of the Convention and paragraph 7 of the Convention Protocol. ... The old convention limited taxation of periodic pension payments, it did not limit the taxation of any other payments out of a "pension" plan nor did it expand upon the meaning of pensions to identify specific sources of the periodic payments as does the present Convention. ...

2007 Ruling 2005-0149681R3- Article XXI of Canada-US Tax Convention Unedited CRA Tags Article XXI Canada-US Tax Convention Principal Issues: Will the non-resident corporation carry on a business in Canada for the purposes of paragraph 3 of Article XXI of the Canada-US Tax Convention? ... The above rulings are based on the Act and the Tax Convention in their present form and do not take into account any proposed amendments to the Act or Tax Convention. ... OPINION The word "income" is not defined in the Tax Convention or in the Income Tax Act. ...

24 April 1990 Ruling HBW84131/4125J1 (E) F- Canada-Japan Income Tax Convention on Employment Income Unedited CRA Tags n/a 19(1) B. ... As a continuing resident of Canada, any employment income earned outside the JET Programme is subject to income tax in Canada pursuant to Article 15 of the Canada-Japan Income Tax Convention. ... Participants in the JET Programme are governed by Article 18 of the Convention and are exempt from tax in Canada based on the unique nature of the Programme.  ...