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.), as amended to the date hereof, and, unless otherwise stated, statutory references in this letter are to the Act; (b) "business" has the meaning assigned by subsection 248(1); (c) "Canadian corporation" has the meaning assigned by subsection 89(1); (d) "Canco" means XXXXXXXXXX; (e) "carrying on business" includes the extended meaning under subsection 253(1); (f) "corporation" has the meaning assigned by subsection 248(1); (g) "paid-up capital" has the meaning assigned by subsection 89(1); (h) "Plan" means the XXXXXXXXXX; (i) "public corporation" has the meaning assigned by subsection 89(1); (j) "Service Provider" as per Section XXXXXXXXXX of the Plan, means an employee or insider (as defined in the Plan) of Canco or any of its subsidiaries and any other person or company engaged to provide ongoing management or consulting services for Canco or for any entity controlled by Canco; (k) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); (l) "Treaty" means the Canada-United Kingdom Tax Convention signed on September 8, 1978, as amended; and (m) "UKCO" means XXXXXXXXXX. ...

Étant donné que les conventions collectives prévoient que le salaire est versé à toutes les deux semaines et qu'il est impensable que les employés ne reçoivent aucun montant durant deux semaines lors de la transition, un montant équivalant à une paie normale pourrait être versé lors de la transition. ...

Yves Leclerc Division de la politique législative 957-3328 Marc LeBlond Direction des décisions en impôt 946-3261 Le 11 octobre 2002 2002-015673 ROUND-TABLE ON FEDERAL TAXATION APFF- 2002 CONVENTION Question 5 Double taxation caused by a reallocation of taxable income earned in a province by a corporation Opco is a corporation with some permanent establishments in Quebec and in other provinces. ...

Nancy Deslandes, CGA 957-8961 Le 11 octobre 2002 2002-015706 ROUND-TABLE ON FEDERAL TAXATION APFF- 2002 CONVENTION Question 36 Removing support payments from the tax system Mr. ...

We note that Article XIII of the Canada-US Tax Convention does provide some relief from double taxation in respect of gains realized on disposition of capital properties. ...

Our understanding of the facts, proposed transactions, purpose of the proposed transactions, and additional information is as follows: Definitions In this letter: “Canco” means XXXXXXXXXX; “GP Co” means XXXXXXXXXX, the general partner of each XXXXXXXXXX LP; “Limited Partners” means the limited partners of each XXXXXXXXXX LP; “LPA” means the limited partnership agreement of each XXXXXXXXXX LP; “Particular Interest Payment” means a particular interest payment made by Canco on the XXXXXXXXXX Loans to a particular XXXXXXXXXX LP as described in paragraph 16 under the heading “Proposed Transactions”; “UK” means the United Kingdom of Great Britain and Northern Ireland; “UK Limited Partners” means those limited partners of a particular XXXXXXXXXX LP who are resident in the UK for purposes of the UK Tax Treaty; “XXXXXXXXXX Loans” has the meaning set out in paragraph 12 under the heading “Facts”; “XXXXXXXXXX LP” means XXXXXXXXXX; and “UK Tax Treaty” means the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital Gains, as Amended by the Protocols Signed on April 15, 1980, October 16, 1985, May 7, 2003 and July 21, 2014. ...

Il n'y a aucune convention écrite entre Mme A et Mme B à l'égard de la Société de Personnes. ...

Subject to the provisions of the Canada-XXXXXXXXXX Income Tax Convention, withholding tax under Part XIII of the Act will apply to such dividend. ...

Income Tax Convention (1980) provided that the value of the outstanding shares of Canco is not derived principally from real property situated in Canada as defined in the afore-noted Article XIII; and (F) Section 245 will not be applied as a result of the proposed transactions, in and by themselves, to redetermine the tax consequences confirmed in the rulings given. ...

Paragraph 81(1)(a) specifically provides that amounts which are declared to be exempt from tax by virtue of another Act of the Parliament of Canada, that are not otherwise exempted by virtue of a tax convention or agreement with another country, are not to be included in computing a taxpayer's income.... ...