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NOTICE273 GST/HST Rulings Service- Eligibility of Tours under the Foreign Convention and Tour Incentive Program Notice to the reader Reference in this publication is made to supplies that are subject to the GST or the HST. ...

Organizations- Under Article XXI of the Canada- United States Tax Convention We have archived this page and will not be updating it. ...

In order for an IRA plan to qualify for purposes of a Letter of Exemption, the custodian/trust/individual must provide the CRA with the following information: The name of the beneficial owners of the IRAs The Tax Identification Number of the beneficial owners The addresses of the beneficial owners A notarized affidavit as to the country of residence of the holder of the IRAs and either a hard copy of the IRAs approved adoption agreement of an Individual Retirement Plan/Trust Agreement a hard copy of the custodian’s Individual Retirement Plan/Trust Agreement, and a hard copy of the fully completed IRS Form 5305 or 5305A (Name and Address) (Officer’s Name) International and Ottawa Tax Services Office Telephone: 1-855-284-5946 (Canada & USA) or: (613) 940-8499 Fax: (613) 941-6905 Attention: (Client’s Name) Date Dear Madam/Sir: Re: We are writing in response to your letter of (date), concerning application for exemption under Article XXI, Paragraph 1 of the Canada-United States Income Tax Convention (1980) (the Convention). We have reviewed your application and based on the information provided we are of the view that xxxxxxxxx as presently constituted, qualifies under Article XXI(1), of the Convention, for exemption from Canadian withholding tax on(type(s) of income) income received from Canadian sources. ... Pursuant to paragraph 4 of Article XXI of the Convention, this exemption does not apply to income earned in Canada by the organization from carrying on a trade or business, or to income from a “related person” other than a person referred to in paragraphs 1 or 2 of Article XXI of the Convention. ...

In order for an IRA plan to qualify for purposes of a Letter of Exemption, the custodian/trust/individual must provide the CRA with the following information: The name of the beneficial owners of the IRAs The Tax Identification Number of the beneficial owners The addresses of the beneficial owners A notarized affidavit as to the country of residence of the holder of the IRAs and either a hard copy of the IRAs approved adoption agreement of an Individual Retirement Plan/Trust Agreement a hard copy of the custodian’s Individual Retirement Plan/Trust Agreement, and a hard copy of the fully completed IRS Form 5305 or 5305A Paragraph 1 Letter (Name and Address) (Officer’s Name) Sudbury Tax Centre Telephone: 1-855-284-5946 (Canada & USA) or: (613) 940-8499 Fax: 1-855-215-6932 (Canada & USA) or: (705) 671-0342 Attention: (Client’s Name) Date Dear Madam/Sir: Re: We are writing in response to your letter of (date), concerning application for exemption under Article XXI, Paragraph 1 of the Canada-United States Income Tax Convention (1980) (the Convention). We have reviewed your application and based on the information provided we are of the view that xxxxxxxxx as presently constituted, qualifies under Article XXI(1), of the Convention, for exemption from Canadian withholding tax on(type(s) of income) income received from Canadian sources. ... Pursuant to paragraph 4 of Article XXI of the Convention, this exemption does not apply to income earned in Canada by the organization from carrying on a trade or business, or to income from a “related person” other than a person referred to in paragraphs 1 or 2 of Article XXI of the Convention. ...

Organizations- Under Article XXI of the Canada- United States Tax Convention From: Canada Revenue Agency Revised March 31, 2024 T4016(E) Rev.24 Clients who want a Letter of Exemption should write to the Sudbury Tax Center at the following address: Non-Resident Withholding Section Canada Revenue Agency Article XXI Post Office Box 20000, Station A Sudbury ON P3A 5C1 For more information about Letters of Exemption call us at 1-855-284-5946 (Canada and the United States), or 613-940-8499 (Outside Canada and the United States), or by fax us at 1-866-765-8460 (Canada and the United States) or 1-705-677-7712 (Outside Canada and the United States). ... Income Tax Convention with effect to March 31, 2022. Letter of Exemption Requirements: Paragraph 1 Under Paragraph 1 of Article XXI, we require the following information prior to issuing a Letter of Exemption: Articles of incorporation (to verify the purpose of the organization, the trustee information, dissolution clause, and the not-for-profit clause) A letter of favorable determination within 10 years of being issued from the Internal Revenue Service (IRS) stating that the organization is tax exempt under 501(c)(3) of the Internal Revenue Code or Form 6166 stating that the organization is recognized as a tax exempt organization per 501(c)(3) and resident in the United States Information concerning the types of income received from sources within Canada, and Address of organization Paragraph 2 Under Paragraph 2 of Article XXI, we require the following information prior to issuing a Letter of Exemption: A letter from the IRS stating that the plan is tax exempt pursuant to the Internal Revenue Code Plan documents are required to verify the: non-diversion of funds dissolution clause trustee information effective date of the trust, trustee signature, and name and address of the plan Individual Retirement Accounts (IRAs) are also exempt under Paragraph 2 of Article XXI. ... New York New York 10004-1936 09-21-2025 174330 The Nebraska Medical Center New York New York 10004 09-25-2026 175796 The New Balance Foundation Boston Massachusetts 2110 06-15-2026 175008 The North American Mission Board of the Southern Baptist Convention Inc New York New York 10004 07-12-2025 161455 The Norton Simon Foundation Bournemouth, Dorset BH7 7DA 09-26-2025 167189 The Oregon Community Foundation Towlerton, Ballysimon, Limerick V94 X2N9 null 06-23-2027 175910 The Overbrook Foundation New York New York 10004 03-12-2027 175874 The Paestum Foundation Inc New York New York 10004-1936 11-15-2026 176072 The Paul G. ...

Box 119 – Foreign business income that is exempt from Canadian tax due to a tax convention or agreement (multi-jurisdictional) Enter any part of foreign business income that is exempt from Canadian tax due to a tax convention or agreement. ... Box 112 – Foreign net rental income that is exempt from Canadian tax due to a tax convention or agreement (multi-jurisdictional) All partners – Enter any part of foreign rental income that is exempt from Canadian tax due to a tax convention or agreement. ... Box 157 – Foreign capital gains exempt from Canadian tax due to a tax convention or agreement (Multi-jurisdictional) Enter the foreign capital gain that is exempt from Canadian tax due to a tax convention or agreement. ...

Example 21 A non-resident person will attend a convention in Canada. The sponsor of the convention has booked a block of rooms at a hotel at a convention rate. ... Packages that include a convention facility or related convention supplies Packages that include a convention facility or related convention supplies are not eligible tour packages. Example 28 The sponsor of a convention hires an organizer to put on a convention that will be held in Manitoba. ...

Canada-Norway Tax Convention – Agreement between Competent Authorities regarding Article 11 (Interest) As provided for under Article 11, paragraph 3(c) of the Canada-Norway Tax Convention, the Competent Authorities for Canada and Norway have agreed to exempt Export Credit Norway from tax in Canada in respect of any interest arising in Canada and paid to it after September 30, 2014. ...

Box 119 – Foreign business income that is exempt from Canadian tax due to a tax convention or agreement (multi-jurisdictional) Enter any part of foreign business income that is exempt from Canadian tax due to a tax convention or agreement. ... Box 112 – Foreign net rental income that is exempt from Canadian tax due to a tax convention or agreement (multi-jurisdictional) All partners – Enter any part of foreign rental income that is exempt from Canadian tax due to a tax convention or agreement. ... Box 157 – Foreign capital gains exempt from Canadian tax due to a tax convention or agreement (Multi-jurisdictional) Enter the foreign capital gain that is exempt from Canadian tax due to a tax convention or agreement. ...

Foreign conventions If you are the sponsor of a foreign convention, you cannot register for the GST/HST if your only commercial activity in Canada is making sales of admissions or related convention supplies or leasing exhibition space at a foreign convention. ... Note Sponsor of a convention means the person who convenes the convention and supplies admissions to it. ... Unregistered non-resident exhibitors attending domestic or foreign conventions can claim a rebate of the GST/HST paid on convention space and related convention supplies. ...