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Income Tax Convention ("U.S. Treaty") Canada-U.K. Tax Convention ("U.K. ...

Income Tax Convention (the "Convention") removes the basic withholding tax exemption granted under that Article where the income is derived from a "related person". ... Department's Position The term "related person" is not defined in the Convention. ... In the context of Article XXI of the Convention "related person" has the meaning assigned in the Act. ...

Income Tax Convention Position: Yes Reasons: Existing posistion that such corps are liable to tax in U.S. 951142 XXXXXXXXXX David R. ... Income Tax Convention (the "Convention"). We apologize for the delay in responding. Article I of the Convention provides that the Convention is generally applicable to persons who are residents of either Canada or the United States. ...

Income Tax Convention (1942) (the "1942 Convention") and 25 percent under the Canada-U.S. Income Tax Convention (1980) (the "1980 Convention"). The case of Indalex Limited v. ... It is our view that payments under paragraph 245(2)(b) of the Act will fall within Article III (Other Income) of the 1980 Convention and will be subject to 25 percent withholding tax. ...

Income Tax Convention (1980) (the Convention) where the payment is a payment on or in respect of a copyright in respect of the production or reproduction of any literary work. ... Accordingly, Canada is required by virtue of the Convention to reduce the rate of withholding tax in respect of the computer software to 10 per cent. ... XXX We are enclosing a copy of Articles XII and XXI of the Convention together with the appropriate technical explanations for your perusal and trust this explanation of Canadian law adequately explains our position. ...

Provincial and International Relations Division have indicated that such arrangements on social security do not override the Act and would also have no effect on income tax agreements or conventions. The only tax agreement or convention which we are aware of which overrides the Act concerning social security payments is paragraph 5 of Article XVIII of the Canada-U.S. Income Tax Convention (Convention). In the case of the United States, we have indicated that, in the calculation of taxable income of a U.S. resident under section 217 of the Act, the individual would be permitted a paragraph 110(1)(f) deduction win respect of benefits received from OAS and CPP/QPP pursuant to paragraph 5 of Article XVIII of the Convention. ...

4 February 1981 Income Tax Severed Letter RRRR34- Canada-Australia treaty — treatment of capital gains and dividends Unedited CRA Tags 2(3), 115(1)(b), 84, 212.1, Canada–Australia Income Tax Convention Dear XXX This is in reply to your letter of December 29 concerning the Canada-Australia Income Tax Convention (1980) (the Convention) which has yet to be ratified. ... We agree that in the absence of the effect of a tax convention, subsection 2(3) of the Income Tax Act would apply and tax would be payable by Mr. and Mrs. ... We have perused the Convention and there is no specific Article dealing with the alienation of capital property you have described. ...

7 December 1991 Income Tax Severed Letter- Employment income earned while on an aircraft in international traffic Unedited CRA Tags Canada-Switzerland tax convention Articles XV, III Canada- Switzerland Tax Convention Article XV, Paragraph 3 This is in reply to your memos dated November 28 and December 3, 1991 regarding the above matter. ... Paragraph 3 of Article XV of the Canada- Switzerland Tax Convention (the "Convention") states that, notwithstanding the preceding provisions of that Article (Dependent Personal Services), remuneration in respect of an employment exercised aboard on aircraft operated in international traffic by an enterprise of a Contracting State, shall be taxable only in that State. ... It would be easier to make a case that the above result was not intended if the language of the subject Article was peculiar to the Convention, however this is not the case. ...

Income Tax Convention Art. 13 922996 XXXXXXXXXX Jim Wilson (613)957-2123 Attention: XXXXXXXXXX December 11, 1992 Dear Sirs: Re: Canada-U.K. Income Tax Convention (the "Convention") We are writing in reply to your letter dated September 29, 1992, in which you requested our comments on the application of paragraph 9 of Article 13 of the Convention under the following hypothetical set of facts: Facts 1. ... Our Comments Based on the understanding that the taxpayer, immediately after his departure from Canada, will be a resident of the U.K. for purposes of the Convention as defined in Article 4 therein, paragraph 9 of Article 13 of the Convention will not apply. ...

It is our understanding that you are concerned with the treatment of such a gain and the related foreign tax credits provided in Article XXIV of the Canada-United States Income Tax Convention (Convention). ... However, paragraph 3(a) of that Article states that Canada and the United States must respect certain provisions of the Convention. ... Article XXIV- Canada-United States Income Tax Convention (new) Article XIII- Canada-United States Income Tax Convention (new) ...