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Our comments Interpretation Bulletin IT-131R2 explains the deduction provided under subsection 20(10) of the Income Tax Act ("the Act") in respect of convention expenses. Paragraph 1 of IT-131R2 defines a convention as a formal meeting of members for business or professional purposes. ... There is no provision in section 8 of the Act that would provide an employee with a deduction for convention expenses. ...

We would point out that this is a different issue than whether Hong Kong is covered by the Canada-China Income Tax Convention (the "Convention") and thereby considered to be part of a "designated treaty country" for purposes of determining "exempt earnings" under our foreign affiliate rules. ... Paragraph 1 of Article 3 (General Definitions) of the Convention defines the term "the People's Republic of China" to mean (for purposes of the Convention) "all of the territory of the People's Republic of China... in which the laws relating to Chinese tax apply...." The term "Chinese tax" is defined in paragraph 1 of Article 2 (Taxes Covered) of the Convention and does not include taxes imposed under Hong Kong's tax regime. ...

Your inquiry also relates generally to other Income Tax Conventions to which Canada is a party that do not include an "Other Income" Article comparable to Article XXII of the Canada-United states Income Tax Convention, 1980. We note that in certain cases the "Business Profits" Article of the applicable Income Tax Convention will deal with the matter raised by you.  ... Treaty (or the comparable provision of the applicable Income Tax Convention if a Convention not having an "Other Income" Article other than the U.K. ...

19 June 1989 Income Tax Severed Letter RRRR152- Canada and Sweden—non-resident owned investment corporation Unedited CRA Tags Canada-Sweden treaty Article 23 This is in reply to your letter of March 29, 1989 concerning paragraph 2(d)(i) of Article 23 of the Canada-Sweden Income Tax Convention (1983) (the "Convention"). ... The issue is whether the dividend payment to Sweden from the NRO is exempt from Swedish tax under paragraph 2(d)(i) of Article 23 of the Convention. ... Based on our interpretation of the Article and the intention of the Convention, we are of the view that a dividend from the NRO to Swedenco in the situation set out in paragraph 2 above would probably not be exempt, by virtue of paragraph 2(d)(i) of Article 23 of the Convention, from Swedish tax. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Subject: E. William Abrahamson v. ... Income Tax Convention (the "Convention"), but amounts subsequently paid out of the IRA are considered to be pension benefits pursuant to subparagraph 56(1)(a)(i). ... Secondly, even if a tax free roll to an IRA under the Convention implied that subsequent payments from the IRA were taxable, the Convention was effective only from 1980 and was not in force in 1975. ...

For the payment to be taxable in Canada it must be considered to be "remuneration for labour or for services" within the meaning of those words in Article XI of the Canada-Netherlands Income Tax Convention (1957) (the "Convention"). ... Accordingly, in our opinion we would have great difficulty in sustaining a position that the retroactive severance pay in question constituted remuneration for labour or services for purposes of Article XI of the Convention. ... With respect to the retroactive pay and vacation settlements, it is our opinion that they do constitute remuneration for labour or for services within the meaning of Article XI of the Convention and therefore are subject to tax in Canada. ...

For the payment to be taxable in Canada it must be considered to be "remuneration for labour or for services" within the meaning of those words in Article XI of the Canada-Netherlands Income Tax Convention (1957) (the "Convention"). ... Accordingly, in our opinion we would have great difficulty in sustaining a position that the retroactive severance pay in question constituted remuneration for labour or services for purposes of Article XI of the Convention. ... With respect to the retroactive pay and vacation settlements, it is our opinion that they do constitute remuneration for labour or for services within the meaning of Article XI of the Convention and therefore are subject to tax in Canada. ...

Campbell XXXX Re: Canada-United States Income Tax Convention XXXX We have your letter of March 7, 1985, regarding the interpretation of Article XVIII of the above-noted tax convention. ... Article XVIII of the Convention sets out the rules applying to payments from pension plans. ... The Convention did not refer to lump sum payments and thus the domestic rate would have applied, except that the Convention indicated that no rate would be applied above 15 per cent. ...

Tier I benefits are the equivalent of U.S. social security benefits and are covered by paragraph 5 of Article XVIII of the Canada-United States Income Tax Convention (Convention). However, Tier II benefits are considered to be private pension plan benefits and are covered by paragraphs 1 and 2 of Article XVIII of the Convention. ... In summary, paragraph 1 of Article XVIII of the Convention would exempt from income in Canada amounts that would be excluded from taxable income in the United States if the taxpayer were a resident thereof. ...

Tier 1 benefits are equivalent to U.S. social security benefits and as such are subject to paragraph 5 of Article XVIII of the Canada- United States Income Tax Convention (1980) (the "Convention"). With aspect to Tier 11 payments, these benefits are considered to be private pension plan benefits and are addressed by Article XVIII of the Convention. ... The portion that is exempt pursuant to paragraph 1 of Article XVIII of the Convention is deductible by virtue of subparagraph 110(i)(f)(i) of the Act in computing taxable income. ...