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Current CRA website

Conventions

Is the convention a domestic or a foreign convention? Domestic convention 27. ... The term "organizer" of a convention means a person who acquires the convention facility or related convention supplies and who organizes the convention for another person who is the sponsor of the convention. ... Domestic conventions 94. As mentioned in paragraph 27, a domestic convention is a convention that is not a foreign convention. ...
Current CRA website

Conventions

Is the convention a domestic or a foreign convention? Domestic convention 27. ... The term "organizer" of a convention means a person who acquires the convention facility or related convention supplies and who organizes the convention for another person who is the sponsor of the convention. ... Domestic conventions 94. As mentioned in paragraph 27, a domestic convention is a convention that is not a foreign convention. ...
Old website (cra-arc.gc.ca)

Guidance on Competent Authority Assistance Under Canada's Tax Conventions

Tax Convention, it is not entitled to the benefits under that Convention that require the person to be a resident of a contracting state. ... Tax conventions usually provide time limits for the taxpayer to present a case to the competent authority of taxation not in accordance with the convention. ... Tax Convention (1980) (the Convention) 64. The Convention contains certain specific provisions to relieve double taxation, as described below. ...
Current CRA website

Guidance on Competent Authority Assistance Under Canada's Tax Conventions

Tax Convention, it is not entitled to the benefits under that Convention that require the person to be a resident of a contracting state. ... Tax conventions usually provide time limits for the taxpayer to present a case to the competent authority of taxation not in accordance with the convention. ... Tax Convention (1980) (the Convention) 64. The Convention contains certain specific provisions to relieve double taxation, as described below. ...
Current CRA website

Guidance on Competent Authority Assistance Under Canada's Tax Conventions

Tax Convention, it is not entitled to the benefits under that Convention that require the person to be a resident of a contracting state. ... Tax conventions usually provide time limits for the taxpayer to present a case to the competent authority of taxation not in accordance with the convention. ... Tax Convention (1980) (the Convention) 64. The Convention contains certain specific provisions to relieve double taxation, as described below. ...
Old website (cra-arc.gc.ca)

Questions and answers - Convention on Mutual Administrative Assistance in Tax Matters

What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ... When was the Convention established? Q3. Why was the Convention updated in 2010? ... When will the updated Convention come into force? Q1. What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ...
Current CRA website

Questions and answers - Convention on Mutual Administrative Assistance in Tax Matters

What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ... When was the Convention established? Q3. Why was the Convention updated in 2010? ... When will the updated Convention come into force? Q1. What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ...
Old website (cra-arc.gc.ca)

Guidelines for Taxpayers Requesting Treaty Benefits Pursuant to Paragraph 6 of Article XXIX A of the Canada-U.S. Tax Convention

Article XXIX A Article XXIX A of the Convention CRA Canada Revenue Agency Competent Authority The Minister of National Revenue or the Minister's authorized representative the Convention The Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital Signed on September 26, 1980, as amended. ... United States of America Part I- Purpose and Scope of Article XXIX A of the Convention 3. Persons that are resident of the U.S. under Article IV of the Convention are entitled to the benefits of the Convention only if they satisfy the requirements set out in Article XXIX A. ...
Current CRA website

Guidelines for Taxpayers Requesting Treaty Benefits Pursuant to Paragraph 6 of Article XXIX A of the Canada-U.S. Tax Convention

Article XXIX A Article XXIX A of the Convention CRA Canada Revenue Agency Competent Authority The Minister of National Revenue or the Minister's authorized representative the Convention The Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital Signed on September 26, 1980, as amended. ... United States of America Part I- Purpose and Scope of Article XXIX A of the Convention 3. Persons that are resident of the U.S. under Article IV of the Convention are entitled to the benefits of the Convention only if they satisfy the requirements set out in Article XXIX A. ...
Current CRA website

Competent Authority Assistance under Canada’s Tax Conventions

Canada’s tax conventions contain an article which is similar to Article 9 of the OECD Model Convention, which addresses transfer pricing adjustments. ... Specific issues under the Canada–United States Tax Convention (1980) (the Convention) Notification pursuant to Article IX (Related Persons) and Article XXVI (MAP) 79. ... The Convention (Canada-United States tax convention) does not have time limits for Articles XXVI and IX, but unlike all of Canada’s other treaties, the Convention does have a notification provision for both Articles XXVI and IX. 80. ...

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