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Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Computer Software Payments Article XIIIC of the Canada-U.S. Tax Convention We have recently been informed by an international accounting firm that the U. ... Tax Convention to be applicable to computer software payments paid by a U. ...

Income Tax Convention I have an income tax problem with the U.K. Inland Revenue which I hope you may be of assistance. XXXX As you are probably aware, the Canada/U.K. tax conventions were amended on 1st April 1966 whereby my pension would be taxed by the U.K. rather than by Canada. ... I was under the impression that the Canada/U.K. tax convention allowed for only one of the countries to claim a tax. ...

Income Tax Convention will apply to all provisions of the 1942 Canada-U.S. ... Income Tax Convention and Article XXXXR, paragraph 5 of the new Canada-U.S. Income Tax Convention. Yours very truly, XXXX ...

17 April 1991 Income Tax Severed Letter 24(1) 5-910837 Jim Wilson 19(1) (613) 957-2120 April 17, 1991 19(1) This is in reply to your letter of March 19, 1991 in which you questioned whether we would consider an exempt charitable organization situate in Israel to be "resident of a Contracting State" for purposes of Article IV of the Canada- Israel Income Tax Convention (the "Convention"). This will confirm that for the purposes of the Convention and other income tax treaties comparable thereto we are of the opinion that an exempt organization that is created or organized in a Contracting State will generally be considered to be a "resident of" that State notwithstanding that it is granted exemption from tax in such State by the tax law thereof. Accordingly an exempt charitable organization that is resident in Israel will be entitled to the benefit of Article XXI of the Convention (ie. reduced withholding rate of 15%) on income arising in Canada from an estate or trust. ...

Claude Lemelin 957-2126 Chief, Policy and Research Section 910309 Application of Article XXVII, Paragraph 2 of the Canada-United Kingdom Income Tax Convention (the "Convention") to Capital Gains Your File No: 19023 This is in reply to your Memorandum dated January 18, 1991. We are of the opinion that Paragraph 2 of Article XXVII of the Convention does not apply to capital gains. ... Furthermore, the Convention refers to income and capital gains (i.e. gains) separately and thus recognizes and maintains the distinction between the two. for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch 000254 ...

Income Tax Convention (1980) (the "Convention") Guarantee Fees This is in response to your memorandum of March 24, 1988 wherein you have requested our opinion whether guarantee fees are considered interest for the purposes of Article XI, paragraph 4 of the Convention. ... Accordingly, since paragraph 214(15)(a) of the Canadian Income Tax Act (the "Act") deems guarantee fees paid to a non-resident to be interest for the purposes of Part XIII of the Act, it is our view that they also constitute interest for the purposes of the Convention. ...

("Prévost B.V.) was the beneficial owner of dividends paid to it from Prévost Car Inc. and therefore, Prévost B.V. was entitled to the 5% withholding rate under Article 10 of the Canada-Netherlands Income Tax Convention. ... Income Tax Convention, as well as the "beneficial owner" principle as now defined by the courts. ENDNOTES 1 Double Taxation Conventions and the Use of Conduit Companies, adopted by the OECD Council on November 27, 1986 2 Organization for Economic Co-operation and Development, Model Tax Convention on Income and on Capital ...

CANADA- BELGIQUE ART. 20 Unedited CRA Tags CONVENTION FISCALE CANADA- BELGIQUE Principales Questions: LE CLIENT DÉSIRE SAVOIR SI L'ARTICLE 20, "ÉTUDIANT", DE LA CONVENTION FISCALE ENTRE LE CANADA ET LA BELGIQUE PERMET D'EXEMPTER DE L'IMPÔT CANADIEN LA RÉMUNÉRATION QU'IL A REÇUE À TITRE DE STAGIAIRE BELGE AU CANADA Position Adoptée: À LA LUMIÈRE DES INFORMATIONS QU'IL NOUS A SOUMISES, NOUS SOMMES D'AVIS QUE LA RÉMUNÉRATION QU'IL A REÇUE AU CANADA NE SE QUALIFIE PAS À L'EXEMPTION PRÉVUE À L'ARTICLE 20 DE LA CONVENTION FISCALE CONCLUE ENTRE LE CANADA ET LE ROYAUME DE BELGIQUE. ... Flaherty, ministre des Finances, m’a fait parvenir une copie de votre courriel, que j’ai reçue le 2 mars 2012, concernant la convention fiscale entre le Canada et le Royaume de Belgique. Vous désirez savoir si l’article 20, « Étudiants », de la convention fiscale entre le Canada et la Belgique permet d’exempter de l’impôt canadien la rémunération que vous avez reçue à titre de stagiaire belge au Canada. ...

Reasons: Article 18 of the Canada-Hungary tax convention. XXXXXXXXXX 2005-016060 November 2, 2006 Dear Sir: Re: Social security/state pension benefits from Hungary This is in reply to your letter of November 21, 2005 in which you requested our opinion concerning the taxation of an amount of social security/state pension benefits received by a Canadian resident from the Republic of Hungary. ... Pursuant to subparagraph 4(c) of Article 18 of the Canada-Hungary Tax Convention (the "Convention"), Canada cannot tax pensions and allowances paid under the social security legislation of Hungary and received by Canadian residents so long as the social security payments are not subject to tax in Hungary. ... Where subparagraph 4(c) of Article 18 of the Convention does not apply, Canada may tax a pension and annuity arising in Hungary pursuant to paragraph 1 of Article 18 of the Convention. ...

NOTE- The taxpayer is not a U.S. citizen so that the treatment provided for in paragraph 5 of Article XXIV of the Convention is not an issue. ... Income Tax Convention (the "Convention"), the U.S. may only tax dividends paid by a U.S. resident to a Canadian resident individual at a rate of 15% of the gross amount. ... U.S. tax paid not in accordance with the Convention) is a voluntary tax and would not be considered an income or profits tax. ...