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.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 RRSPs and RCAs not treated as flow-through entities under Art. ...

8 September 2017 External T.I. 2014-0549771E5- Article XXIX-A:3-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 "person related thereto" defined by ITA meaning of "related person" After noting the relevance of domestic definitions of a term under Art. ...

14 December 1992 Income Tax Severed Letter 912281A F- PROFESSIONS DÉPENDANTES\AVANTAGES EN VERTU D'UN EMPLOI-- summary under Subsection 7(4) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(4) A Canadian employee who exercised an employee stock option after becoming a non-resident of Canada would be taxable in Canada on the benefit subject to the provisions of any tax convention. ...

18 April 2001 External T.I. 2001-0074995 F- Indemnité journalière de grossesse de France-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) French maternity allowances were taxable CCRA indicated that daily pregnancy benefits paid by the French government constituted income which was taxable for Canadian tax purposes, and was not exempted under the Canada-France Convention. ...

9 January 2001 External T.I. 2000-0042545- Immovable property-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The exception for real property in which the business of the enterprises carried on apparently was viewed as being available where the shares of a private corporation resident in Canada actively carried on a farming business in Canada. ...

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Convention. ...

Convention, assuming the lender is a U.S. resident. ...

Income Tax Convention, the Canadian-resident shareholder of an S-Corp will not obtain a Canadian foreign tax credit for the U.S. tax paid by him in respect of the income of the S-Corp unless he had income from other sources of the United States that was subject to Canadian income tax. ...

17 July 1992 T.I. 920168 (January- February 1993 Access Letter, p. 35, ¶C180-134)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Whether an arrangement under which the U.S. seller assigned its receivables, or nominated a U.S. bank as its agent to collect the receivables, gave rise to a change in beneficial ownership of the interest on the receivables could only be determined after an examination of the relevant documentation. ...