Search - convention

Déduction d'impôt prévue par la Convention si le contribuable a des revenus de la France dans l'année du décès. ... Le paragraphe 1e) de l'article XXIII de la Convention n'a pas pour objet de permettre d'accorder une déduction pour impôt étranger à l'égard de l'ISF. Le paragraphe 1e) de l'article XXIII de la Convention est identique au paragraphe 3 de l'article 23A du Modèle de Convention Fiscale de l'OCDE. ...

Income Tax Convention (the “Convention”) but the U.S. tax so imposed should not exceed certain tax rates provided by the Convention (the “treaty rate(s)”). ... Before the Third Protocol, paragraph 5 of Article XXIV of the Convention required that Canada provide a tax credit equal to the lesser of the amount of U.S. tax otherwise payable or 15% of the gross amount of each item of income referred to in that paragraph regardless of the rate that such item of income was taxed by the U.S. under the Convention. ... In the mean time if the tax imposed by the U.S. after tax credits on an item of income referred to in paragraph 5 of Article XXIV of the Convention as amended by the Third Protocol exceeds what is allowed under the Convention, you may suggest the taxpayer to seek the assistance of Competent Authority in Canada to resolve the issue. ...

Income Tax Convention (the “U.S. Convention”) This is in reply to your memorandums of April 24th and 30th in which you requested clarification as to whether the provisions of paragraph 2(a) of Article XXI of the U.S. ... Convention, income referred to in Article X (Dividends) and XI (Interest) of the U.S. ... Convention, this would depend on the actual facts surrounding each particular payment. ...

Reasons: Interpretation of the provisions of the Act and Articles 3, 15 and 27A of the Canada-United Kingdom Income Tax Convention ("UK Convention"). ... In the situation set out above, there is no relief from taxation in Canada under the Canada-United Kingdom Income Tax Convention (the "UK Convention"). Our analysis of the relevant provisions of that convention is as follows. ...

Plus particulièrement, vous désirez savoir si l'entité crée aux termes de la Convention de fiducie intervenue le XXXXXXXXXX (la " Convention ") constitue une fiducie pour les fins de la Loi de l'impôt sur le revenu (la " Loi "). ... Selon l'information que vous nous avez transmise, la Convention serait régie par la common law. ... " (p. 109) En l'espèce, il nous apparaît que les termes de la Convention établissent clairement l'intention de XXXXXXXXXX de créer une fiducie aux termes de la Convention. ...

Income Tax Convention (the "Convention") issued by the U.S. government and agreed to by the Department of Finance. ... S. credits, as required by paragraphs 4(b) and 5(c) of Article XXIV of the Convention, allowed for Canadian taxes paid or accrued. ... S. income tax return and the application of U.S. tax credits in accordance with Article XXIV of the Convention. ...

Whether the treaty provides any relief for royalties under the Canada-US Tax Convention and the Canada-France Tax Convention Position: Yes. ... Nichols 2011-039276 April 19, 2011 Dear XXXXXXXXXX: RE: Motion picture films- subsection 212(5) of the Income Tax Act We are writing in reply to your letter dated January 13, 2011 requesting our view whether subsection 212(5) of the Income Tax Act (the "Act") would apply to certain payments for rights to motion picture films made to non-residents and whether relief is available under the Royalties articles of the Canada-US Tax Convention (the "US Convention") and the Canada-France Tax Convention (the "France Convention"), based on the following facts. 1. ... Canco has entered into a second contract under which it will pay a fee to a French distribution company that is a resident of France for purposes of the France Convention, for a right in or the use of certain motion pictures. 3. ...

Reasons: (1) Article XVIII, paragraph 1 of the Convention (2) Article XVIII, paragraph 7 of the Convention. ... However, in many cases, Article XVIII of the Convention Between Canada and the United States of America with Respect to Taxes on Income and on Capital (the "Convention") may apply to defer or relieve taxation in Canada. ... Subparagraph 3(b) of Article XVIII of the Convention provides that if a Canadian resident individual makes contributions to his or her Roth IRA while a resident of Canada, the Roth IRA will cease to be considered a "pension" for purposes of the Convention at the time of the contribution. ...

Tax Convention (the "U.S. Convention") and the resident of the second country is entitled to benefits under Canada's treaty with the second country. ... The LLC is owned one-third each by a U.S. resident, a resident of another country with which Canada has an income tax convention, and a resident of a third country with which Canada does not have an income tax convention. ... Tax Convention, we would not be opposed if you took the view, administratively, that the purchaser may file a T2062C Notice in respect of the LLC. ...

Furthermore, section 18 of Article V of the Convention on the Privileges and Immunities of the United Nations ("Convention") provides exemption from tax to those United Nations officials on the salaries and emoluments paid to them by the United Nations. ... As the ICJ is the principal judicial organ of the United Nations, the Department would recognize any tax exemptions granted to it or its employees and officials pursuant to the Convention on the Privileges and Immunities of the United Nations ("Convention"). ... As pension income from the ICJ is taxable under the Act, the Department must then consider the application of an income tax convention to ensure that Canada's right to tax has not been restricted or denied by the application of that particular convention. ...