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Income Tax Convention (1980) (the "Convention") Guarantee Fees This is in response to your memorandum of March 24, 1988 wherein you have requested our opinion whether guarantee fees are considered interest for the purposes of Article XI, paragraph 4 of the Convention. ... Accordingly, since paragraph 214(15)(a) of the Canadian Income Tax Act (the "Act") deems guarantee fees paid to a non-resident to be interest for the purposes of Part XIII of the Act, it is our view that they also constitute interest for the purposes of the Convention. ...

("Prévost B.V.) was the beneficial owner of dividends paid to it from Prévost Car Inc. and therefore, Prévost B.V. was entitled to the 5% withholding rate under Article 10 of the Canada-Netherlands Income Tax Convention. ... Income Tax Convention, as well as the "beneficial owner" principle as now defined by the courts. ENDNOTES 1 Double Taxation Conventions and the Use of Conduit Companies, adopted by the OECD Council on November 27, 1986 2 Organization for Economic Co-operation and Development, Model Tax Convention on Income and on Capital ...

CANADA- BELGIQUE ART. 20 Unedited CRA Tags CONVENTION FISCALE CANADA- BELGIQUE Principales Questions: LE CLIENT DÉSIRE SAVOIR SI L'ARTICLE 20, "ÉTUDIANT", DE LA CONVENTION FISCALE ENTRE LE CANADA ET LA BELGIQUE PERMET D'EXEMPTER DE L'IMPÔT CANADIEN LA RÉMUNÉRATION QU'IL A REÇUE À TITRE DE STAGIAIRE BELGE AU CANADA Position Adoptée: À LA LUMIÈRE DES INFORMATIONS QU'IL NOUS A SOUMISES, NOUS SOMMES D'AVIS QUE LA RÉMUNÉRATION QU'IL A REÇUE AU CANADA NE SE QUALIFIE PAS À L'EXEMPTION PRÉVUE À L'ARTICLE 20 DE LA CONVENTION FISCALE CONCLUE ENTRE LE CANADA ET LE ROYAUME DE BELGIQUE. ... Flaherty, ministre des Finances, m’a fait parvenir une copie de votre courriel, que j’ai reçue le 2 mars 2012, concernant la convention fiscale entre le Canada et le Royaume de Belgique. Vous désirez savoir si l’article 20, « Étudiants », de la convention fiscale entre le Canada et la Belgique permet d’exempter de l’impôt canadien la rémunération que vous avez reçue à titre de stagiaire belge au Canada. ...

Reasons: Article 18 of the Canada-Hungary tax convention. XXXXXXXXXX 2005-016060 November 2, 2006 Dear Sir: Re: Social security/state pension benefits from Hungary This is in reply to your letter of November 21, 2005 in which you requested our opinion concerning the taxation of an amount of social security/state pension benefits received by a Canadian resident from the Republic of Hungary. ... Pursuant to subparagraph 4(c) of Article 18 of the Canada-Hungary Tax Convention (the "Convention"), Canada cannot tax pensions and allowances paid under the social security legislation of Hungary and received by Canadian residents so long as the social security payments are not subject to tax in Hungary. ... Where subparagraph 4(c) of Article 18 of the Convention does not apply, Canada may tax a pension and annuity arising in Hungary pursuant to paragraph 1 of Article 18 of the Convention. ...

NOTE- The taxpayer is not a U.S. citizen so that the treatment provided for in paragraph 5 of Article XXIV of the Convention is not an issue. ... Income Tax Convention (the "Convention"), the U.S. may only tax dividends paid by a U.S. resident to a Canadian resident individual at a rate of 15% of the gross amount. ... U.S. tax paid not in accordance with the Convention) is a voluntary tax and would not be considered an income or profits tax. ...

Our comments Interpretation Bulletin IT-131R2 explains the deduction provided under subsection 20(10) of the Income Tax Act ("the Act") in respect of convention expenses. Paragraph 1 of IT-131R2 defines a convention as a formal meeting of members for business or professional purposes. ... There is no provision in section 8 of the Act that would provide an employee with a deduction for convention expenses. ...

We would point out that this is a different issue than whether Hong Kong is covered by the Canada-China Income Tax Convention (the "Convention") and thereby considered to be part of a "designated treaty country" for purposes of determining "exempt earnings" under our foreign affiliate rules. ... Paragraph 1 of Article 3 (General Definitions) of the Convention defines the term "the People's Republic of China" to mean (for purposes of the Convention) "all of the territory of the People's Republic of China... in which the laws relating to Chinese tax apply...." The term "Chinese tax" is defined in paragraph 1 of Article 2 (Taxes Covered) of the Convention and does not include taxes imposed under Hong Kong's tax regime. ...

Your inquiry also relates generally to other Income Tax Conventions to which Canada is a party that do not include an "Other Income" Article comparable to Article XXII of the Canada-United states Income Tax Convention, 1980. We note that in certain cases the "Business Profits" Article of the applicable Income Tax Convention will deal with the matter raised by you.  ... Treaty (or the comparable provision of the applicable Income Tax Convention if a Convention not having an "Other Income" Article other than the U.K. ...

19 June 1989 Income Tax Severed Letter RRRR152- Canada and Sweden—non-resident owned investment corporation Unedited CRA Tags Canada-Sweden treaty Article 23 This is in reply to your letter of March 29, 1989 concerning paragraph 2(d)(i) of Article 23 of the Canada-Sweden Income Tax Convention (1983) (the "Convention"). ... The issue is whether the dividend payment to Sweden from the NRO is exempt from Swedish tax under paragraph 2(d)(i) of Article 23 of the Convention. ... Based on our interpretation of the Article and the intention of the Convention, we are of the view that a dividend from the NRO to Swedenco in the situation set out in paragraph 2 above would probably not be exempt, by virtue of paragraph 2(d)(i) of Article 23 of the Convention, from Swedish tax. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Subject: E. William Abrahamson v. ... Income Tax Convention (the "Convention"), but amounts subsequently paid out of the IRA are considered to be pension benefits pursuant to subparagraph 56(1)(a)(i). ... Secondly, even if a tax free roll to an IRA under the Convention implied that subsequent payments from the IRA were taxable, the Convention was effective only from 1980 and was not in force in 1975. ...