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Treaty withholding DRI Healthcare is expected to be eligible for benefits under the United States Tax Convention with Ireland and will generally not be subject to any U.S. withholding taxes on such U.S. ...

" Canadian Treaty exemption Under Canada-Peru Tax Convention, Rio Alto Shareholders who are resident or deemed resident in Canada for the purpose of that Treaty will be exempt from Peruvian tax on any gain arising from the exchange. ...

" Commercial Trust The Commercial Trust will be treated as a corporation resident in Canada; and it is expected that it will be eligible for the benefits of the Canada-US Income Tax Convention (the "Treaty"), so that interest on the US Holdco Note will be exempt from withholding under the Treaty. ...

BBP LP may allocate items of income, gain, loss, and deduction using a monthly convention, whereby any such items recognized in a given month by it are allocated to unitholders as of a specified date of such month. ...

Non-resident unitholders A Non-Resident Trust Unitholder will not be subject to tax under the Tax Act on any capital gain realized on the disposition of Trust Units under the Redemption, unless (i) the Trust Units disposed of are "taxable Canadian property" (as defined in the Tax Act) of the Non-Resident Trust Unitholder at the time of the disposition, and (ii) the Non-Resident Trust Unitholder is not exempt from taxation in Canada on the disposition of such shares pursuant to an applicable income tax treaty or convention. ...

A non-resident Shareholder will not be subject to tax under the Tax Act in respect of any capital gain realized on the disposition of Shares under the Offer unless the Shares are "taxable Canadian property" to the Non-Resident Shareholder at the time of such sale and such gain is not otherwise exempt from tax under the Tax Act pursuant to the provisions of an applicable income tax convention (if any). ...

Non-resident unitholders It is unclear whether qualifying U.S. residents (who otherwise would benefit under Article XXII of the Canada-US Convention from the 0% withholding tax rate applicable to distributions made out of income arising outside Canada, and a 15% rate applicable to income arising in Canada) would have that benefit denied under the anti-hybrid rule in Art. ...

However, the CRA's administrative practice in similar circumstances is to permit the rate of Canadian federal withholding tax applicable to such payments to be computed by looking through a partnership and taking into account the residency of its partners (including partners who are resident in Canada) and any reduced rates of Canadian federal withholding tax that any non-Canadian limited partners may be entitled to under an applicable income tax treaty or convention, provided that the residency status and entitlement to treaty benefits can be established. ...