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XXXXXXXXXX January 30, 2004 Income Tax Appeals Division Sophie Chatel 333 Laurier Avenue West Ottawa ON K1A 0L9 Attention: Janine Dunphy 2004-005498 Social Security Payments under the Canada-Cyprus Convention- Article 18 This is in reply to your enquiry of January 6, 2004 wherein you requested our views on application of the Canada-Cyprus Convention (the "Convention") in respect of payments under Canada's social security system. ... Paragraph 5 of Article 18 of the Convention provides that social security pensions arising in Canada and paid to a resident of Cyprus are only taxable in Canada. ... Moreover, paragraph 1 of the Convention also provides that the first CND$10,000 of pension payments (periodic payments or lump sum payments) are exempt from tax in the country in which they arise. ...

28 April 1992 External T.I. 9134875 F- Article 24 Canada-Cyprus Tax Sparing Provisions Unedited CRA Tags 20(11), 20(12)      5-913487 24(1)     O.Laurikainen      (613)957-2116 Attention: 19(1) April 28, 1992 Dear Sirs: Re: Canada-Cyprus Income Tax Convention This is in response to your letter dated December 17, 1991 requesting a technical interpretation as to the effect of Article 24 of the Canada-Cyprus Income Tax Convention (the "Convention").  ... It is our view that under paragraph 1(a) of Article 24 of the Convention the words "and unless a greater deduction or relief is provided under the laws of Canada... ... In response to your query concerning the form of certificate required for the purposes of paragraph 2(a) of Article 24 of the Convention, we note only that we are unaware of any guidelines.  ...

Income Tax Convention. Position: Yes, in the situation described in the memo. Reasons: Because Article XXIX B of the Convention only applies to the year of death. ... Income Tax Convention (the "Convention") We are writing to reply to your request for our comments on a statement made by your client with respect to the interaction of subsection 104(4)of the Act and paragraph 6 of Article XXIX B of the Convention. ...

Income Tax Convention (the "Convention"). In brief, you have described a situation where a Canadian public corporation ("Canco") carries on a manufacturing and processing business in Canada and its assets include cash and marketable securities, land and building and Class 43 depreciable property. ... Section 3 of the Income Tax Conventions Interpretation Act ("ITCIA") reads, in part, as follows: "Notwithstanding the provisions of a convention or the Act giving the convention the force of law in Canada, it is hereby declared that the law of Canada is that, to the extent that a term in the convention is (a) not defined in the convention, (b) not fully defined in the convention, or (c) to be defined by reference to the laws of Canada, that term has, except to the extent that the context otherwise requires, the meaning it has for the purposes of the Income Tax Act,...... ... " We are also of the opinion that paragraph 3(c) of the ITCIA would include those terms defined in a convention by "reference to the taxation laws of Canada" (e.g. see the wording used in paragraph 2 of Article VI of the Convention) because the phrase "laws of Canada" is clearly broader than the phrase "taxation laws of Canada". ...

Therefore, the Convention removes the obligation of a Canadian resident to pay U.S. income tax in excess of the amount that would have been paid under the Convention. ... The result would be the same if the taxpayer opts out of the Convention. ... AMT arises in spite of the Convention not because of the Convention. Example E (Canadian Source Income with Some U.S. ...

Therefore, the Convention removes the obligation of a Canadian resident to pay U.S. income tax in excess of the amount that would have been paid under the Convention. ... The result would be the same if the taxpayer opts out of the Convention. ... AMT arises in spite of the Convention not because of the Convention. Example E (Canadian Source Income with Some U.S. ...

Leung (613) 957-2115 Attention: XXXXXXXXXX February 17, 1995 Dear Sirs: Re: Paragraph 250(1)(a) of the Income Tax Act (the "Act") and Articles IV and XV of the Canada-United States Income Tax Convention (the "Convention") We are writing in response to your letter of January 3, 1994 in which you requested our views on certain matters in connection with paragraph 250(1)(a) of the Act and Articles IV and XV of the Convention. ... We do not feel that such an interpretation would lead to any conflict or inconsistency between the Act and the Convention. ... For income that Canada has a right to tax, he may find relief in the manner of a reduced tax rate under the Convention. ...

17 February 2014 Internal T.I. 2013-0498121I7- Follow up to XXXXXXXXXX CRA Tags Vienna Convention on Diplomatic Relations Article 39 162(7) Vienna Convention on Diplomatic Relations Article 34 Principal Issues: Is a diplomatic agent exempt from a penalty under 162(7) as a result of filing a notice of disposition late? ... February 17, 2014 Legislative Policy Directorate HEADQUARTERS Legislative Policy and Regulatory Income Tax Rulings Affairs Branch Directorate Attention: France Marengère Katharine Skulski (613) 957-8585 2013-049812 Vienna Convention We are writing in reply to your request for our comments regarding whether the Vienna Convention on Diplomatic Relations (the "Convention") would exempt a diplomatic agent and/or his child from liability for a penalty under subsection 162(7) of the Income Tax Act (the "Act"). ... For the same reasons, the convention would not exempt the child from taxes. ...

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère. 931269 XXXXXXXXXX Jim Wilson (613) 957-2123 Attention: XXXXXXXXXX September 3, 1993 Dear Sirs: Re: Canada-Jamaica Income Tax Convention (the "Convention") This is in reply to your letter dated April 28, 1993, in which you requested our interpretation of paragraph 2 of Article XIX of the Convention. ... In our opinion the tax levied under subsection 120(1) of the Act applies to the computation of "the amount of tax" as referred to in paragraph 2 of Article XIX of the Convention. ... Accordingly, we are of the view that the tax under subsection 120(1) of the Act falls within the spirit of paragraph 2 of Article XIX of the Convention. ...

Income Tax Convention would continue to apply if repayment terms and interest rate modified. ... Income Tax Convention (the "Convention") This is in reply to your letter of March 12, 1996, wherein you request our views concerning the interpretation of paragraph 3(d) of Article XI of the Convention in the following hypothetical fact situation: Canco acquires machinery and equipment from USco. ... Canco and USco are not "related persons" within the meaning of that term in paragraph 3(d) of Article XI of the Convention. ...