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Income Tax Convention (1980) Unedited CRA Tags 20(1)(v.1), Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. VI, XIII This memorandum is in response to yours of June 27, 1989 in which you requested our opinion concerning the characterization of property as real property situated in Canada which, upon alienation by a resident of the United States, can result in a taxable gain in Canada pursuant to Article XIII of the Treaty. ...

16 January 1990 Income Tax Severed Letter ACC8919- Canada-Netherlands Income Tax Convention- Pension of Public Employees January 16, 1990 Provincial and International Relations Division J. ... Solley Manager, Public Affairs Penticton District Office 19(1) Canada-Netherlands Tax Convention Article 18 We are writing in reply to your memorandum dated July 27, 1989, concerning the above-noted taxpayer. ...

3 December 1990 Administrative Letter 903016 F- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags n/a 19(1) 903016   M.P. ...

1 March 1990 Income Tax Severed Letter ACC9218- Canada-USSR Income Tax Convention Unedited CRA Tags Canada-U.S.S.R. ...

7 December 1990 Income Tax Severed Letter- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags Canada–Germany Income Tax Agreement Dear Sir: Re: Article 13 of the Canada-Germany Income Tax Agreement (1981) (the “Agreement”) We are writing in reply to your letter dated October 18, 1990 wherein you brought to our attention the fact that the assumption made in our letter dated August 14, 1990 that the West-German “Gesellschaft des buergerlichen Rechts” (“GbR”) is a private corporation is not correct. ...

2001 Ruling 2000-0056883 F- MODIFICATION CONVENTION D'ACHAT D'ACTIONS Unedited CRA Tags 110(1)(d) 7(3)b) 7(1)b) 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. ... Est-ce que l'alinéa 7(1)b) s'applique dans le cas où un employé a le droit de choisir une somme en espèces plutôt que des actions en vertu d'une convention d'achat d'actions? ... La convention d'achat d'actions prévoit que des modifications peuvent être effectuées (E9632153,E9618951, E990140, E9818203). 2. et 3. ...

22 October 1990 Internal T.I. 901787 F- Determination of Residence under Canada-Germany Income Tax Convention Unedited CRA Tags n/a 24(1) 901787   L.A. ...

Income Tax Convention Unedited CRA Tags 126(1), 20(12), 20(11) 24(1) 902469   R.S. ...

Income Tax Convention Unedited CRA Tags 20(11), 20(12), 126 Dear Sirs: This is in answer to your letter of September 6, 1990 concerning section 126 of the Income Tax Act (the Act) with respect to a Canadian resident individual who owns shares of a U.S. corporation which corporation elects to be taxed as a subchapter S corporation. ...

Tax Convention Unedited CRA Tags Article IV(7)(b) Principal Issues: Whether Article IV(7)(b) of the Treaty applies to fees paid by a Canadian unlimited liability corporation ("ULC") to a U.S. limited partnership Position: No Reasons: The treatment of the fees under the income tax laws of the U.S. is the same as it would be if the ULC were not fiscally transparent XXXXXXXXXX 2009-034590 XXXXXXXXXX, 2009 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX (the "taxpayers") This is in response to your XXXXXXXXXX request for an advance income tax ruling on behalf of the above taxpayers. ... X" means XXXXXXXXXX; (i) "Partnership A" means XXXXXXXXXX.; (j) "Partnership B" means XXXXXXXXXX.; (k) "Province" means XXXXXXXXXX; (l) "qualifying person" has the meaning assigned by Article XXIX-A of the Treaty; (m) "related persons" has the meaning assigned by subsection 251(2) of the Act; (n) "S Corp" means XXXXXXXXXX.; (o) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (p) "taxation year" has the meaning assigned by subsection 249(1) of the Act; (q) "Treaty" means the Convention Between Canada and the United States of America With Respect to Taxes on Income and Capital Signed on September 26, 1980 as Amended by the Protocols Signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007; and (r) "United States" means the United States of America. ...