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.-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Retirement compensation arrangement as pension (p. 493) [U]nder the model convention, payments from an RCA are likely to be considered a pension rather than income from employment. From a Canadian perspective, pursuant to the Income Tax Conventions Interpretation Act (ITCIA), RCAs are considered to be pension vehicles if "pension is not otherwise defined in the tax convention concluded between Canada and a foreign country. Advantage if OECD Model followed (p. 493) Article 18 of the model convention provides that pension benefits are taxable only in the state of residence of the beneficiary. ...

Veronika Solilová, Marlies Steindl, "Tax Treaty Policy on Article 9 of the OECD Model Scrutinized", OECD, Bulletin for International Taxation, March 2013, p. 128, at 130-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 In the course of reviewing the background to Article 9(2) of the OECD Model Convention, they stated: …According to Working Party 7, article 9 of the OECD Draft (1963) "serves a useful purpose as a statement of what Contracting Parties to Double Taxation Conventions have in Mind". ...

.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Discussion of Article IV(7)(b) of the Canada-U.S. Income Tax Convention. ...

Jack Bernstein, "Fiscally Transparent Entities and the Canada-US Treaty", Canadian Tax Highlights, Vol. 20, No. 1, January 2012-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The rules in Articles IV(6) and (7) of the Canada-US Convention might be summarized by stating that if the taxpayer and the fiscally transparent entity reside in the same country, treaty benefits apply. ...

Scott Wilkie, "Services Permanent Establsihments and the Canada-United States Income Tax Treaty", International Transfer Pricing Journal, Vol. 19, No. 3, 2012, p. 179-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Discussion of para. 9 of Art. V of the Canada-US Convention. ...

Finley, "Payments Out of a RCA May Not Be Eligible for Reduced Withholding Tax", Taxation of Executive Compensation and Retirement, September 1990, p. 327-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 RC has accepted that an RCA which has been established in order to fund supplemental pension benefits for an employee is a "superannuation, pension or retirement plan" for purposes of Article XVIII of the U.S. Convention; however, RC will insist on the benefits being available as a result of retirement, and not as a consequence of loss of employment. ...

Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Scope of withholding exemption/reduced withholding for period pension payments (p. 32:15) The Canada-UK treaty…eliminates withholding for periodic pension payments, which may be applicable to certain payments from RRSPs, RRIFs, RCAs and CPP and OAS benefits. "Periodic pension payment" is defined in section 5 of the Income Tax Conventions Interpretation Act as a payment from a pension (for example, a registered pension plan, an RRSP, an RRIF, an RCA, CPP and OAS), subject to certain exceptions. ...