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Tax Convention Canada-U.S. Tax Treaty:Art. X, XI, XII 922332 24(1) K. ... Income Tax Convention (the "Convention") This is in reply to your letter of July 28, 1992 wherein you requested our opinion concerning Article XXII of the Convention in respect to the following hypothetical situation. ... Interest paid by a U.S. resident, for the purposes of the Convention, will be deemed to arise in the United States pursuant to paragraph 6 of Article XI of the Convention. ...

The entry into force of the proposed Convention between Canada and the United States can only take place when all issues covered by the Convention have been finalized. ... On June 14, 1983, the two countries signed a Protocol to amend the earlier Convention. ... It should be noted that the current Canada-United States Income Tax Convention remains in effect until it has been superceded by the proposed Convention. ...

It is our view that it is arguable that the term "income" used in Article 21 of the Canada-Australia Income Tax Convention (1980) does not include capital gains since the Convention mentions gains specifically where it is intended that these be included. ... In addition, there arises no inconsistency between the provisions of the Income Tax Act and the Convention which would cause the Convention to prevail pursuant to subsection 6(2) of the Canada-Australia Income Tax Convention Act, 1980, so as to limit Canada's right to tax the capital gains in question. ... In summary, we are of the view that under the Convention with Australia, Canada has not given up its right to tax capital gains. ...

X peut être déclaré et imposé qu'en Suisse aux termes des articles XV et XVII de la Convention. ... X, en vertu des articles XV et XVII de la Convention, les revenus de ce dernier ont été correctement déclarés en Suisse. ... L'assujettissement des revenus est fondé initialement sur la législation fiscale des pays signataires, mais il peut être réduit en fonction des dispositions de la convention fiscale entre des pays signataires, les conventions fiscales ayant préséance sur la législation fiscale domestique. ...

Principal Issues: General questions on application of Singapore tax convention. ... Does the Convention apply to personal income tax? 2. Does the Convention apply such that once you pay Singapore income tax you are "waived from paying" Canadian income tax? ... Question 1 The Convention applies to all types of income tax imposed by Canada and Singapore. ...

Income Tax Convention (the "Convention") This is in reply to your letter of November 13, 1992. ... The partners are all residents of the United States for the purposes of the Convention. ... The Convention will not affect Canada's right to tax under that provision. ...

Income Tax Convention (1980) (the "current Convention") entered into force on August 16, 1984 you were of the view that the statement concerning such royalties pertained to the current Convention since IC 77-16R2 was issued more than three months after the entry into force of the current Convention. ... Tax Convention.  Payments under perpetual or unlimited term agreements are not affected by this interpretation. ... Income Tax Convention (1942) (the "1942 Convention"). It has been our opinion since the Saint John Shipbuilding case (80 DTC 6272) that payments made to U.S. residents for the use of computer software under perpetual or unlimited agreements would not constitute rental or royalties for the purpose of the 1942 Convention and therefore such payments would not be subject to withholding tax.  ...

Income Tax Convention (1980) (the "current Convention") entered into force on August 16, 1984 you were of the view that the statement concerning such royalties pertained to the current Convention since IC 77-16R2 was issued more than three months after the entry into force of the current Convention. ... Tax Convention. Payments under perpetual or unlimited term agreements are not affected by this interpretation. ... Income Tax Convention (1942) (the "1942 Convention"). It has been our opinion since the Saint John Shipbuilding case (80 DTC 6272) that payments made to U.S. residents for the use of computer software under perpetual or unlimited agreements would not constitute rental or royalties for the purpose of the 1942 Convention and therefore such payments would not be subject to withholding tax. ...

Convention") or paragraph 5 of Article XIV of the Canada-Barbados Income Tax Convention (the "Barbados Convention"). ... Convention or paragraph 5 of Article XIV of the Barbados Convention to apply. ... Convention or Barbados Convention is relevant to determine whether Canada has the right to tax the gain. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI, XXI 922104 24(1) K.B. Harding 957-2111 Attention: 19(1) October 20, 1992 Dear Sirs: Re: Article XI of the Canada-U.S. ... Income Tax Convention (the "Convention") clearly provides that for purposes of Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information Article XI of the Convention that interest is deemed to arise in the United States and not in Canada in the situation described above. ... Since the sourcing rule set out in paragraph 6 of Article XI is applicable only for the purposes of Article XI of the Convention, it does not change the Canadian sourcing rules for purposes of Article XXII (Other Income) of the Convention. ...