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Income Tax Convention is relevant for the purposes of paragraphs 4 and 5 of Article XIII of the Convention? Does the term alienation in the Convention include a deemed disposition pursuant to 128.1(4) of Act? ... It is our view that, for the purposes of applying paragraphs 4 and 5 of Article XIII (Gains) of the Convention, the residency of the alienator of the property would be as determined under Article IV (Residence) of the Convention. ...

Income Tax Convention- U.S. Estate Tax Unedited CRA Tags n/a 24(1) 902998   G. Arsenault   (613) 957-2126 19(1) December 10, 1990 Re:  Canada-United States income Tax Convention, 1980 (the "Convention")- U.S. ... It is our understanding that United States estate tax is not a tax on capital and that Article XXIII of the Convention is not applicable thereto. ...

Income Tax Convention- Mineral Resource Unedited CRA Tags 7(b), 12(1)(o), 18(1)(m), 248(1) minerals 5-8539 Dear Sirs: Re:  Article 13 of the Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter dated August 21, 1989.  ... We apologize for the delay in responding to you, which arose because we considered it necessary to undertake consultations with the Department of Finance in connection with subparagraph 7(b) of Article 13 of the Convention. ... Having regard to the definition of "minerals" in subsection 248(1) and the provisions of and the amendments proposed in July of 1990 to paragraphs 12(1)(0) and 18(1)(m) of the Act, paragraph 2 of Article 3 of the Convention and informal advice we have received from the Department of Energy, Mines and Resources, we are of the opinion that coal is included in "petroleum, natural gas or other related hydrocarbons" within the meaning of that term as used in paragraph 4 of Article 13 of the Convention. ...

1 October 1990 Ministerial Letter 901828 F- Canada-Japan Income Tax Convention on Capital Gains Unedited CRA Tags n/a 24(1) 901828   G. Arsenault   (613) 957-2126 19(1) October 1, 1990 Dear Madam: Re:  Canada-Japan Income Tax Convention (1986) (the "Convention") This is in reply to your letter dated August 3, 1990. In our opinion, residents of Japan are not granted any exemption from Canadian tax on capital gains by the Convention. ...

13 November 1990 Ministerial Letter 901998 F- Canada-Italy Tax Convention Unedited CRA Tags 217, 110(1)(f)(i)   November 13, 1990 WINDSOR DISTRICT OFFICE HEAD OFFICE P. ... Biscaro   (613) 957-2122 Attention: Edward Hooft International Audit 901998 SUBJECT:  Canada-Italy Tax Convention (the "Convention") We have been asked to reply to your memorandum of July 24, 1990 to Christine Savage, Acting Director, Provincial and International Relations Division concerning Article XVIII of the Convention which deals with pension receipts. ... With respect to the Canada-Italy Convention, the legislators effectively wrote the elective provisions of section 217 of the Act into paragraph 1(b) of Article XVIII of the Convention for purposes of determining the applicable tax rate. ...

25 July 2005 External T.I. 2005-0119811E5- Article 13 of Canada-Germany Tax Convention Unedited CRA Tags Article 13(4)(b) Principal Issues: whether an interest in a partnership, less than 50% of the value of which is attributable to immoveable property situated in a country, will be subject to tax in that country Position: Generally, no Reasons: subparagraph 4(b) of Article 13 of the Convention XXXXXXXXXX 2005-011981 T. Harris (613) 957-2114 July 25, 2005 Dear XXXXXXXXXX: Re: Article 13 of the Canada- Germany Tax Convention We are writing in response to your email message of March 7, 2005 wherein you requested our comments regarding the interpretation of Article 13 of the Canada- Germany Tax Convention (the "Convention"). ... Subparagraph 4(b) of Article 13 of the Convention provides that: "4. ...

9 October 2009 Roundtable, 2009-0327021C6 F- Liquidation d'une convention de retraite Unedited CRA Tags 248(1) Principales Questions: Un arrangement qui est une convention de retraite continue-t-il de recevoir le traitement fiscal applicable à une convention de retraite lorsqu'il est liquidé prématurément? ... APFF- Table ronde sur la fiscalité des stratégies financières et des instruments financiers- CONGRÈS 2009 Question 7- Liquidation d'une convention de retraite et qualification à titre de convention de retraite L'ARC s'est prononcée sur la qualification de régimes de retraite à titre de convention de retraite lors de la table ronde sur les produits financiers au congrès annuel de 2005 de l'Association de planification fiscale et financière. ... De plus, les conjonctures économiques peuvent faire en sorte que la convention de retraite soit plus coûteuse que prévue. ...

Income Tax Convention Unedited CRA Tags Canada/U.s. Treaty, Art. 15 Dear Sirs: Re:  Article XV(2)(b) of the Canada-United States Income Tax Convention. 1980 (the "Convention")  This is in reply to your letter dated December 6, 1990. Your proposed representation of the Department's position concerning the application of the above-noted provision of the Convention where a United States parent company ("U.S.Co. ... In our opinion, whether or not a resident of Canada is an "employer" for purposes of subparagraph 2(b) of Article XV of the Convention is essentially a question of fact.  ...

Income Tax Convention on Capital Gains Unedited CRA Tags n/a   November 20, 1989 TO  Montreal District Office FROM  Specialty Rulings   Directorate S. ... Our position is in line with the view that intent of Article XIII(9) was to effect a transition between the status of United States resident under the 1942 Convention and his status under the 1980 Convention.  ... Under the transitional provisions, in the 1980 Convention the relief therefore is the proportion of the gain from V-Day that accrued prior to December 31, 1984 (before the coming into force of the 1980 Convention).  ...

Income Tax Convention Unedited CRA Tags n/a 19(1) File No. 5-8199   R.C. ... Income Tax Convention (1980) (the "Convention") This is in reply to your letter dated July 24, 1989 regarding the above-referenced matter. ... In our opinion the word "seller" in paragraph 3(d)  of Article XI of the Convention means the original seller and would not include the assignee in either of the situations you have described.  ...