Search - convention

6 March 1991 Memorandum (Tax Window, No. 1, p. 18, ¶1148)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 The rate reduction under Article XVIII of the U.S. Convention applies only to annuity payments made on a periodic basis, and not to a lump-sum payment arising on the surrender or partial surrender of an annuity. ...

1996 Ontario Tax Conference Round Table, Q. 3 (No. 9630040)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 RC has not formulated a position on the essential characteristics of a franchise agreement for purposes of subparagraph 3(c) of Article XII of the U.S. Convention, and it is a question of fact whether an arrangement is "in connection with a rental... agreement". ...

4 March 1992 Memorandum (Tax Window, No. 17, p. 11, ¶1781)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Payments made for the use of a trademark are not exempt under Article XIII(3) of the Canada-U.S. Convention because they are not in respect of copyright. ...

93 C.M.TC- Q. 4-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The continuance of a corporation incorporated in Canada to the United States will not result in that corporation ceasing to be considered to have been created in Canada for purposes of Article IV of the U.S. Convention notwithstanding s. 250(5.1). ...

Round Table, Q. 25-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A capital gain arising as a result of a distribution of paid-up capital on common shares held by a non-resident generally would be exempt under Article XIII(4) of the Canada-U.S. Convention, unless the gain was derived from shares described in paragraphs 1, 2 or 3. ...

.- Q.1-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Withdrawals from RRSP's are pensions for purposes of Article XVIII of the U.S. Convention. However, the reduced rate of 15% only applies where withdrawals from an RRSP are periodic, i.e., a series of payments for providing retirement income for the greater part of the recipient's life. ...

1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A list of nine criteria for determining whether a Canadian corporation is an independent agent of a U.S. corporation for purposes of Article V(7) of the Canada-U.S. Convention. ...

.- F.Q.16-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 The taxes covered under the Convention do not include provincial taxes, and RC cannot ask for information on behalf of the province. ...

Annual Conference, Q. 12 (January- February 1993 Access Letter, p. 54)-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 Conventions are legally binding in Canada from the time they are enacted. ...

.- Q.82-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 administrative policy re requests for reduced withholding based on Article XVII(2) of the U.S. Convention. ...