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Income Tax Convention (1980) (the "Convention"), notwithstanding that the underlying source of that item is a motion picture film. This exemption, however, only relates to such payments made on or after October 1, 1984 as provided by paragraph 2(a) of Article XXX of the Convention. In our view, the above position is in accord with the comments on paragraph 3 of Article XII of the Convention in the U.S. ...

However, pursuant to Article XIIIC of the 1942 Convention and Article XXX of the 1980 Convention, payments made before Network's first taxation year beginning on or after January 1, 1986 will be exempt from withholding tax, except any portion of the payments that are in respect of programming based on motion picture films. To the extent that the payments are in respect of programming based on motion picture films, the withholding tax is limited to 15% pursuant to Article XI of the 1942 Convention. The Part XIII withholding tax on payments made to Network after that time will be reduced to 10% pursuant to Article XII of the 1980 Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII, Canada-France Income Tax Convention Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Income Tax Convention (1980) and the Canada-France Income Tax Convention (1975) to exert from Part XIII withholding tax, royalties payable by a Canadian distributor to either an unrelated U.S. producer corporation or to an unrelated French producer corporation for the right to distribute in Canada various videotapes and videodisc products for home use. ... Income Tax Convention (1980), royalties exempt pursuant thereto include royalties related to the sale or rental of videotapes for private viewing. ...

4 February 1981 Income Tax Severed Letter Dear XXX This is in reply to your letter of December 29 concerning the Canada-Australia Income Tax Convention (1980) (the Convention) which has yet to be ratified. ... We agree that in the absence of the effect of a tax convention, subsection 2(3) of the Income Tax Act would apply and tax would be payable by Mr. and Mrs. ... We have perused the Convention and there is no specific Article dealing with the alienation of capital property you have described. ...

Fioravanti (613) 995-1767 December 17, 1984 Dear Sir: This is in reply to your letter of September 7 requesting our interpretation of the effective rate of "branch tax" provided by Section 219 of the Income Tax Act in light of the 1960 Canada- U.S. lax Convention. You raise the question that in view of the provisions of Subsection 11(4) ITAR and in view of the intention to equate the rate of branch tax to the rate of dividends paid by a subsidiary to its parent, will the provisions of Subsection 11(4) ITAR and the relevant provisions in the new Convention be interpreted to permit a reduction ire the branch tax from 15% to 10% from October 1, 1964 to the effective date of paragraph 6 of Article X of the new Convention (being the first fiscal year of the payer non-resident corporation commencing on or after January 1, 1985): or, does the fact that any additional tax is limited by paragraph 6 of Article X of the new Convention to 10% result in Subsection 11(4) ITAR being inapplicable notwithstanding the fact that the limitation contained in paragraph 6 of Article h of the new Convention does not have effect in respect of the taxation year in respect of which the branch taxes are required to be paid where such taxation year did not commence on or after January 1, 1985? We agree with your latter analysis that the branch tax will not be reduced to 10% prior to the period set out in paragraph 2(b) of Article XXX of the Convention. ...

Income Tax Convention (Convention) This is in reply to your memorandum of November 16, 1987 concerning the treatment of recapture of capital cost allowance under the Convention. It continues to be our general view, for the reasons set out in the letters attached to your memorandum, that Article XIII of the Convention will have application to capital gains derived by a resident of the United States whereas Articles VI, VII, VIII and XIV of that Convention will apply to tax the income, including the recapture of capital cost allowance, which a non-resident earns in Canada. Paragraph 8 of Article XIII of the Convention permits the Canadian competent authority, in the situations set out therein, to agree to defer the recognition of the profit, capital gain or income (including C.C.A.) for Canadian income tax purposes in order to avoid double taxation. ...

The draft Tax Convention between Canada and the United Kingdom was issued to the public on September 8, 1978. ... We regret that we have no alternative but to assess XXXX in accordance with the provisions or the Income Tax Act and the present Canada-United Kingdom Tax Convention. The treaty makes no provision for people who entered into contract prior to the entry into force of the present Convention, other than for situations covered by paragraph 4 of Article 28 of the Convention (copy attached). ...

Short: XXXX is seeking a solution to the following problem relating to paragraph 7 of Article XI of the Canada-United Kingdom Convention (the Convention). ... The technical interpretation of the Convention and the Act is that this interest is subject to 25% withholding tax, even when the interest is physically paid by the United Kingdom branch to the United Kingdom lender. ... Is there a specific reason why the Convention does not contain an "other income" article? ...

It is not a "qualifying person" for the purposes of paragraph XXIX-A(1) of the Convention. 6. ... In general terms, Article XXIX-A of the Convention states that a person that is a resident of a Contracting State and that is not a "qualifying person" may nonetheless be entitled to the benefits of the Convention if one of three exceptions applies. Paragraph XXIX-A(3) of the Convention provides for one of these exceptions. ...

The provisions for taxing business income are found in Article 7 of the Convention. ... Valuable guidance on the interpretation of articles within income tax conventions is provided in the commentary to the OECD Model Tax Convention on Income and Capital (July 2010). ... The definition of "immovable property" is found in paragraph 2 of Article 6 of the Convention. ...