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De plus, selon les dispositions du paragraphe 207.6(2) de la Loi, l’employeur est réputé être le dépositaire d’une convention de retraite. Le droit dans la police d’assurance-vie est réputé être un bien déterminé de la convention de retraite. Un montant égal au double de toute prime versée sur la police est réputé être une cotisation versée dans le cadre de la convention. ...

Income Tax Convention (the "Convention"), Canada has the right to tax this income and the U.S., not Canada, should be granting credit in respect of the Canadian tax. Paragraph 2 of Article XXIX of the Convention states that, except as provided in paragraph 3, nothing in the Convention shall be construed as preventing Canada from taxing its residents and, in the case of the U.S., its citizens, as if the Convention did not exist. ... If the Convention is read without regard to paragraph 2 of Article XXIX, "Canadian source" income received by a resident of Canada would not be subject to tax in the U.S. under the Convention and such income would therefore be deemed to arise in Canada for purposes of Article XXIV. ...

Where the conditions in paragraph 81(1)(c) of the Act are not met, one would then go to the Convention to find out if there is any relief provided by the Convention. ... The term "international traffic" is not defined in the Convention. However, XXXXXXXXXX of the Convention states: "XXXXXXXXXX". ...

Income Tax Convention (the "Convention") This is in reply to your letter of October 19, 1992 wherein you requested our opinion on a number of questions concerning the following hypothetical situation. ... On the assumption that the partnership is not carrying on business in Canada through a permanent establishment and the sale of shares of Canco does not fall within paragraph 1 of Article XIII of the Convention, the pro rata share of the gain realized by the partnership from the disposition of its shares in Canco which flows through to Y will fall within paragraph 4 of Article XIII of the Convention and will not be taxable in Canada. 2. Reasonable management fees which are paid to a resident of a country with which Canada has a tax convention or agreement will generally fall within the business profits article. ...

Convention (1942) as "royalties for the right to use copyright". ... Income Tax Convention (1942) applied to exempt such payments from withholding tax. ... Income Tax Convention (1942) (see The Queen vs. Saint John Shipbuilding and Dry Dock Co. ...

Tax Convention, 110(1)(f), 56(8), 120.3 Principal Issues: What is the correct treatment of a U.S. ... " You also noted that the guidance provided in IT-122R2 appears to contradict paragraph 5 of Article XVIII "Pensions and Annuities" of the Canada- United States Tax Convention (the Convention). ... Article 2 of the Technical Explanations of the Fourth Protocol of the Convention provides an explanation of paragraph 5(a) of Article XVIII of the Convention. ...

Income Tax Convention (1980) (the "Convention") in accordance with Article IV of the Convention ("U.S. ... Pension Fund, Master Trust or Charitable Organization which is constituted in the United States will pursuant to subparagraph (1)(b) of Article IV of the Convention, be considered to be a resident of the United States for the purposes of the Convention. ... E.Provided that a U.S. investor that acquires units of the Fund or a U.S.investor who is a member of a partnership that acquires units of the Fund, did not become a resident of the United States for the purpose of obtaining the benefits of the Convention and can reasonably be considered the beneficial owner of the income distributed by the Fund, the benefits of the Convention will not be denied to the investor as contemplated by paragraph 7 of Article XXIXA of the Convention. ...

Paragraph 7 of Article XXIV of the Convention is the only reference to "state or local income taxes" in the Convention. ... " as that term is used in paragraph 4(a) of Article XXIV of the Convention. ... Therefore, Canada is not obliged to grant a credit for such state tax under the Convention. ...

You have further stated that since the Canada-United Kingdom Income Tax Convention (the "UK Convention"), Article XXVII paragraph 2 denies treaty relief on income not remitted to the UK, it is implicit that the individual is nevertheless regarded as a resident of the UK and subject to the UK Convention even if they receive some income which is not taxed in the UK because it is not remitted. ... As stated in Document No. 1999-0014605, the CCRA's view is that Hong Kong is not covered by the Canada-China Income Tax Convention (the "Chinese Convention") as notwithstanding unification of Hong Kong and the People's Republic of China, Hong Kong has maintained its own tax system and the term "Chinese tax" as defined in the Chinese Convention does not include taxes imposed under Hong Kong's tax regime. ... Accordingly, in our view, the individual was not a resident of the Dominican Republic under the Dominican Republic Convention. ...