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En conséquence, vous êtes d'avis que la Convention devrait s'appliquer dans une situation telle que celle décrite précédemment car en vertu du paragraphe 1(II) de la Convention, celle-ci s'applique non seulement aux droits successoraux mais également à tous autres impôts analogues établis sur les successions. ... Malgré le fait que la Convention soit toujours en vigueur, nous sommes d'avis que celle-ci est devenue désuète depuis l'abrogation de l'imposition des droits successoraux au Canada en 1971. ... Cependant, nous nous devons d'interpréter et d'appliquer la Loi et les conventions fiscales telles que rédigées. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Dear Sirs: This is in reply to your letter dated July 28, 1982 concerning royalties paid to U.S. residents with respect to programs supplied on videotapes. ... Convention (not yet ratified) contains provisions which will terminate the above-mentioned exemption and permit Canada to tax such previously exempted royalties at a rate not to exceed 10%. This tax would not be exigible before the new Convention becomes effective. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII(4) Dear Sirs: Re: Article XII of the Canada-United States Income Tax Convention, 1980 (the “Convention”) This is in reply to your letter dated December 17, 1990. In our opinion, a payment arising in Canada made by a Canadian resident to a person resident in the United States (who does not have a permanent establishment in Canada) for services of an industrial, commercial or scientific character performed by the resident of the United States for the Canadian resident, which payment is dependent in whole or in part upon use, production or sales of goods or services, or profits and is a payment to which subparagraph 212(1)(d)(iii) applies, is not a “royalty” as defined in paragraph 4 of Article XII of the Convention. ...

8 May 1990 Income Tax Severed Letter HBW 4125-S2B Unedited CRA Tags Canada-Switzerland Income Tax Convention Article XXIV HBW 4125-S2 David R. Senécal (613) 957-2074 May 8, 1990 Dear xxxxx Pursuant to paragraph 4 of Article XXIV of the Canada- Switzerland Income Tax Convention signed by our two countries on August 20, 1976, we would like to clarify the application of the said Convention to the taxation of remuneration paid by a political subdivision of a Contracting State to an individual in respect of services rendered to that subdivision. Paragraph 1 of Article XIX of the Convention provides that such remuneration shall be taxable only in the State of source. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII 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. ... Income Tax Convention (1980) (the "Convention"). We are attaching a copy of Article XII of the Convention and a copy of the Technical Interpretation to that article for your information. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Computer Software Payments Article XIIIC of the Canada-U.S. Tax Convention We have recently been informed by an international accounting firm that the U. ... Tax Convention to be applicable to computer software payments paid by a U. ...

Income Tax Convention I have an income tax problem with the U.K. Inland Revenue which I hope you may be of assistance. XXXX As you are probably aware, the Canada/U.K. tax conventions were amended on 1st April 1966 whereby my pension would be taxed by the U.K. rather than by Canada. ... I was under the impression that the Canada/U.K. tax convention allowed for only one of the countries to claim a tax. ...

Income Tax Convention will apply to all provisions of the 1942 Canada-U.S. ... Income Tax Convention and Article XXXXR, paragraph 5 of the new Canada-U.S. Income Tax Convention. Yours very truly, XXXX ...

17 April 1991 Income Tax Severed Letter 24(1) 5-910837 Jim Wilson 19(1) (613) 957-2120 April 17, 1991 19(1) This is in reply to your letter of March 19, 1991 in which you questioned whether we would consider an exempt charitable organization situate in Israel to be "resident of a Contracting State" for purposes of Article IV of the Canada- Israel Income Tax Convention (the "Convention"). This will confirm that for the purposes of the Convention and other income tax treaties comparable thereto we are of the opinion that an exempt organization that is created or organized in a Contracting State will generally be considered to be a "resident of" that State notwithstanding that it is granted exemption from tax in such State by the tax law thereof. Accordingly an exempt charitable organization that is resident in Israel will be entitled to the benefit of Article XXI of the Convention (ie. reduced withholding rate of 15%) on income arising in Canada from an estate or trust. ...

Claude Lemelin 957-2126 Chief, Policy and Research Section 910309 Application of Article XXVII, Paragraph 2 of the Canada-United Kingdom Income Tax Convention (the "Convention") to Capital Gains Your File No: 19023 This is in reply to your Memorandum dated January 18, 1991. We are of the opinion that Paragraph 2 of Article XXVII of the Convention does not apply to capital gains. ... Furthermore, the Convention refers to income and capital gains (i.e. gains) separately and thus recognizes and maintains the distinction between the two. for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch 000254 ...