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16 June 2014 External T.I. 2014-0516451E5- Application of Canada-Israel Tax Convention-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Canadian corporation a Canadian "national" under Canada-Israel tie-breaker If the "mind and management" of a BC venture capital corporation (which was incorporated in Canada) resided in Israel, resort would be necessary to the tie-breaker rule in Art. ...

28 May 2015 IFA Roundtable Q. 12, 2015-0581521C6- IFA 2015 Q.12: Canada-Switzerland Treaty-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions resolution of conflicting French and English Treaty versions of Swiss Treaty in taxpayer's favour A corporation resident in Switzerland ("Swissco") wholly-owns "Holdco," which wholly-owns "Canco"). ...

30 March 2017 External T.I. 2015-0609951E5 F- Article 18 of the Canada-Turkey Income Tax Convention-- summary under Pension Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 5- Pension RRSP annuity payments to Turkish resident were subject to Pt XIII tax as pension payments RRSP annuity payments made to a resident of Turkey were deemed by s. 5 to be pension payments (as “pension” was not specifically defined in the Canada-Turkey Treaty), so that the payments were subject to Canadian withholding at the reduced rate described in Art. 18, para. 2. ...

27 June 1996 External T.I. 9605225- ARTICLE XII US CONVENTION- PAYMENTS FOR USE OF DATABASE-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Payments made by a Canadian resident user to a U.S. resident supplier for accessing an information data base located in the U.S. via a modem located in Canada would be exempt as being for the use of, or the right to use, information concerning industrial, commercial or scientific experience. ...

30 November 1999 External T.I. 9825155- CANADA-UK TAX CONVENTION-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 Where an individual resident of the U.K. owns all the shares of a private Canadian corporation that, in turn, has as its principal asset less than 1% of the shares of a real estate company that is publicly traded on The Toronto Stock Exchange, the exclusion for shares deriving their value "indirectly" from Canadian real estate would apply to a disposition of the shares of the private company even though a direct sale of the shares of the public corporation would be exempt from Canadian capital gains tax. ...

10 November 2000 External T.I. 1999-0008335 F- inclusion revenu exonéré- convention fiscale-- summary under Paragraph 81(1)(a) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(a) requirement to include a treaty-exempt receipt in income Regarding a retirement annuity received by a Canadian resident from a French corporation that was exempted under Article 18 of the Canada-France Tax Convention, CCRA indicated that, by virtue of s. 81(1)(a) (and as confirmed by Swantje) the taxpayer was required to include the retirement annuity in income under s. 56, before taking a deduction under s. 110(1)(f). ...

2012 Ruling 2012-0435211R3- Article XXIX-A(3) of the Canada-US Tax Convention-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Holdco, which had been a listed U.S. company, was taken private by L5, which was a fund whose members are not known. ...

20 December 1994 External T.I. 9421435- ROYALTIES AND CANADA-UK INCOME TAX CONVENTION-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 With respect to a situation where a Canadian company pays royalties to a resident of the U.K. for the right to reproduce certain movies, television series and children's programs in video format with the resulting videos being sold to distributors who would, in turn, rent or sell the videos to the public for private use, RC stated "that if the payments are computed on the basis of the number of times a video movie is shown and/or viewed rather than on the number of copies of the video produced, the payments would not fall within the exemption in paragraph 3 of Article 12 as they would not be considered to be in respect of the production or reproduction of the work". ...

5 February 2001 External T.I. 2000-0032695 F- Convention fiscale Canada-France-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 profits based consulting fee paid to French company with no PE in Canada was exempted under Art. 7 of the Canada-France treaty A CCPC (“Canco”) agreed to pay a French company (“Franceco”) for its consulting services, aimed at identifying and connecting with potential clients in France, a fixed basic fee, as well as an additional variable fee based on the results obtained. ...

10 January 2014 Internal T.I. 2013-0505911I7- Meaning of "assembly project" in Brazil Convention-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "assembly" and "installation" project Art. ...