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2 May 2001 Internal T.I. 2001-007939 F- CONVENTION D'EMISSION D'ACTIONS Unedited CRA Tags 7(1)(a) 7(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Il a notamment soumis un document (Attach B) émanant du fiduciaire désigné par la société pour administrer la convention relative à l'émission des actions. Ce document, que le fiduciaire a émis le XXXXXXXXX, indique que la date d'attribution définitive sera établie comme suit: XXXXXXXXXX Le document ajoute que XXXXXXXXXX Le XXXXXXXXXX, une lettre du fiduciaire indique que le contribuable peut continuer de bénéficier de la convention bien qu'il ait pris sa retraite. ...

9 May 2001 External T.I. 2000-0033775- UK TAX CONVENTION DIVIDENDS Unedited CRA Tags ARTICLE 10 90(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... You are of the view that, since the income earned on the investments held within a PEP or an ISA is exempt from taxes in the U.K. the income earned on such investments should not be taxed in Canada on the basis that your client is entitled to a tax credit in respect of dividends pursuant to Article X(3)(b) of the Canada-United Kingdom Income Tax Convention (1978). ... In order to determine whether receipt of income from PEPs and ISAs may be subject to special tax treatment under the Canada-United-Kingdom Income Tax Convention (1978), we would have to review the structure of each PEP or ISA, the particular investments held therein, and any information slips related thereto. ...

Income Tax Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Income Tax Convention (1980) (the "Treaty") and Partnerships This is in response to your letter dated November 6, 1991 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

Income Tax Convention, 1980 (the "Treaty")] January 22, 1987 Specialty Rulings Directorate G. ... Income Tax Convention, 1980 (the "Treaty") We are returning the six (6) unassessed 1985 returns included with your Round Trip Memorandum ("RTM") of January 7, 1987 concerning an individual's residency status pursuant to the income Tax Act (the "Act") and pursuant to the "tie breaker" rules in Article IV of the Treaty. ... Rather, since the opening words of Article IV read "For the purposes of this convention", those residency rules are relevant only for the purposes of determining the extent to which another Article of the Treaty might exempt certain income from Canadian Tax. ...

Income Tax Convention.] K.B. Harding (613) 957-2129 February 27, 1967 Dear Sirs: This is in reply to your letter of January 26, 1987 concerning Article XVIII (Pensions and Annuities) of the Canada-U.S. income Tax Convention. ... Income Tax Convention includes all amounts received upon or after retirement in recognition of service in an office or employment. ...

19 May 2010 IFA Roundtable, 2010-0366521C6- Canada-United States Tax Convention Unedited CRA Tags Paragraph 78(1)(b) of the Act; Article IV(7)(b) of the Convention Principal Issues: Interaction between paragraph 78(1)(b) of the Act and Article IV(7)(b) of the Convention where an amount of interest is deemed to be received by a resident of the United States from a Canadian Unlimited Liability Company (ULC) that is fiscally transparent under the taxation laws of the United States Position: Article IV(7)(b) applies Reasons: The tax treatment of the amount under the taxation laws of the United States is not the same as it would be if the ULC were not fiscally transparent International Fiscal Association Annual Conference May 19, 2010 Application of Article IV(7)(b) to Paragraph 78(1)(b) Amounts Assume that a Canadian unlimited liability company ("ULC") is wholly-owned by a non-resident corporation ("USCo"). USCo is a resident of the United States for the purposes of the Canada-United States Tax Convention (1980) (the "Treaty"). ...

23 March 2009 Internal T.I. 2008-0304441I7- Gain on shares- Canada-Israel Tax Convention Unedited CRA Tags Article XIII(3) Canada-Israel tax treaty Article XIII(4) Canada-Israel tax treaty Principal Issues: Are the shares of Canholdco held by its Israeli parent considered to be property that consists primarily of immovable property situated in Canada such that Article XIII(3) of the Canada-Israel tax treaty applies? ... Scott CMA HEADQUARTERS International Audit Division Income Tax Rulings London Tax Services Office Directorate Sylvie Labarre, CA 2008-030444 Article XIII(3) of the Canada- Israel Tax Treaty (1975) We are writing in response to your memorandum of December 9, 2008 in which you requested our interpretation of Article XIII of the Canada- Israel Income Tax Convention, 1975 (the "Treaty"). ... However, under certain circumstances that do not seem to arise in your particular situation, CRA will consider the application of the general anti-avoidance rule in section 245 of the Act if it is evident that in contemplation of a sale of the shares of a particular Canadian company a structure was put in place in an attempt to obtain tax relief from an income tax convention. ...

11 February 2010 Roundtable, 2009-0345351C6- Canada-United States Tax Convention (1980) Unedited CRA Tags Article IV(6) of the Convention Principal Issues: Whether a fiscally transparent entity, such as a United States LLC, is eligible to claim benefits under Article X or XI of the Convention on behalf of its member(s) in respect of Canadian-source dividends or interest paid to the LLC in circumstances where the amount paid is disregarded under the taxation laws of the United States or where the treatment of the amount under the taxation laws of the United States differs from its treatment under the taxation laws of Canada Position: See response Canadian Tax Foundation- 2009 Round Table Question 4(d) re: Application of Article IV(6) Before the Fifth Protocol was signed by Canada and the United States (US) in the fall of 2007, it was widely expected that a rule would be introduced to provide treaty benefits to US-owned LLCs. ... CRA Response Article IV(6) of the Canada-United States Tax Convention (1980) ("Treaty") is effective, in respect of taxes withheld at source, for amounts paid or credited on or after February 1, 2009. ...

La question de savoir si un contribuable a disposé d'un droit qu'il a à une part du revenu ou d'une perte d'une société de personnes aux termes de la convention mentionnée au paragraphe 96(1.1) est une question de faits. ... Généralement, l'Agence du revenu du Canada (" ARC ") ne remet pas en question la validité d'une convention de partage d'une société de personnes qui est basée sur l'apport de chaque associé. ... Selon les informations fournies, nous sommes d'avis que la convention de partage n'entrainerait pas l'application du paragraphe 103(1). ...

21 April 1999 External T.I. 9900795- CANADA-US INCOME TAX CONVENTION Unedited CRA Tags 110.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Savage Attention: XXXXXXXXXX April 21, 1999 Dear Sirs: This is in response to your letter of January 8, 1999 regarding paragraph 6 of article XXI of the Canada-United States Income Tax Convention (the “Treaty”). ...