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18 April 1990 Income Tax Severed Letter ACC9185- Canada-China Income Tax Convention on Interest on Deposits Earned in Canada 19(1) Jim Wilson (613) 957-2063 HBW 4125-C2 HBW 6591-C2 April 18, 1990 Dear 19(1) Re: 24(1) Article XI of the Canada-China Income Tax Convention We are writing in regard to your letter dated January 17, 1989 (copy attached), in which you requested confirmation on the tax status of the 24(1) regarding interest earned on deposits held in Canada. Our Vancouver District Office replied to the letter on April 4, 1989 (copy attached) and acknowledged tax exemption to the 24(1) in accordance with paragraph 3, Article 11 of the Canada-China Income Tax Convention. ... Article 3 of Convention delegates the competent authority function to your Ministry of Finance ar its authorized representative. ...

Income Tax Convention, 1980] Revenue Canada Taxation Head Office Attention: XXXX T.B. ... Income Tax Convention, 1980 This is in reply to your letter of July 29 regarding the above-referenced subject. ... Income Tax Convention, 1980 (the "Convention") would apply in a situation where a Canadian resident individual elects under subsection 85(1) of the Act on the transfer of his interest in a U.S. partnership to his wholly-owned Canadian corporation. ...

Income Tax Convention and RCAs] K.B. Harding (613) 957-2129 November 10, 1987 Dear Sirs: This is in reply to your letter of September 10, 1987 concerning the application of the Canada- U.S. Income Tax Convention (Convention) to retirement compensation arrangements (RCAs) as proposed in Bill C-64. ... Paragraph 2 of Article XXI of the Convention also provides an exemption from withholding tax on interest and dividends derived by an organization which is "generally exempt from tax in a taxable year" and is "constituted and operated exclusively to administer or provide benefits under one or more funds or plans established to provide pension, retirement or other benefits". ...

Income Tax Convention- Lump Sum Withdrawal from RRSP Unedited CRA Tags n/a 19(1) File No. 5-9277   D. ... Tax Convention. It is our position that a full or partial lump sum withdrawal from a RRSP would not be considered a pension for purposes of Article XVII(1) of the Canada-U.K. Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

5 October 1989 Ruling HBW41253 F- Canada-Austria Income Tax Convention Unedited CRA Tags n/a 19(1) David R. ... Pursuant to paragraph 3 of article XXV of the Canada-Austria Income Tax Convention (1976) and in our capacity as Canadian competent authority we wish to confirm our agreement with the following interpretation of Article XIX of the said Convention. ...

Income Tax Convention- Lump Sum Withdrawal from RRSP Unedited CRA Tags n/a 19(1) File No. 5-9445   D. ... Tax Convention to lump sum withdrawals from a Registered Retirement Savings Plan (RRSP). ... Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

15 February 1990 Ruling HBW4125U31A F- Canada-US Income Tax Convention- Interest Income Exemption Unedited CRA Tags Can. ... Pursuant to Article XI, subparagraph 3(a) of the Canada-United States Income Tax Convention, interest income arising in Canada and paid to the corporation is exempt from tax in Canada.  ... In the event of a change in status of the Corporation or an amendment or repeal to Article XI of the Convention (i.e. ...

Income Tax Convention on CPP and OAS 19(1) B. Fioravanti 613-957-2073 HBW 4125-U3 HBW 4125-U3-1 December 12, 1989 Dear 19(1) In reply to your letter of November 23, we confirm that benefits received under the Canada Pension Plan and the Old Age Security Act are "benefits under the social security legislation" of Canada within the meaning of paragraph 5 of Article XVIII of the Canada-United States Income Tax Convention. ... The Convention provides that one-half of such benefits will be exempt from tax in the United States. ...

Income Tax Convention- Lump Sum Withdrawal from RRSP 5-9445 D. Duff (613) 957-3498 January 25, 1990 Dear Sirs: This is in reply to the letter of April 7, 1989, from 19(1) of your office, and further to our interim letter of August 8, 1989, concerning the application of Article XVII of the Canada-U.K. Tax Convention to lump sum withdrawals from a Registered Retirement Savings Plan (RRSP). ... Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

Income Tax Convention- Interest and Guarantee Fees Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XI, XIII HBW 9412-2-3 24(1) Jim Wilson (613) 957-2063 EACC8742 February 13, 1990 Dear 19(1) RE: 24(1) We are writing in reply to your letter dated January 15, 1990 concerning the tax status in Canada of the above-noted institution. Pursuant to Article XI of the Canada-United States Income Tax Convention, interest and guarantee fees paid by the 24(1) are exempt from Part XIII withholding tax. ...