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Income Tax Convention (1980) (the "Convention"), notwithstanding that the period over which such payments are made is abbreviated to a period shorter than to age 90 of the recipient. ... Now that the budget has been passed, your inquiry concerns the question of whether an amount paid out of an RRIF in excess of the minimum amount as provided for in paragraphs 146.3(1)(b.1) and 146(1)(f) of the Act qualifies as a periodic pension benefit for purposes of the Convention. ... In addition to examining all the facts this question may require a determination of the intent of the legislators and drafters of the Convention. ...

This individual, once or twice per year, attends a convention sponsored by the Master Franchisor of his employer. ... The individual pays all costs associated with his attendance at such conventions. ... As a consequence, the convention expenses would not be deductible under paragraph 8(1)(f) of the Act. ...

Income Tax Convention (1942) Income Tax Convention Interpretations Act------------------------------------------ This is in reply to your letter of February 15, 1985 wherein you requested confirmation of your understanding of the interaction of the above-referenced laws. ... USCO B does not have a permanent establishment in Canada, as that term is defined in and for the purposes of the 1942 Convention. 2. ... Tax Convention (1942) are applicable. Consequently, a withholding tax must be paid on the deemed dividend. ...

-Canada Income Tax Convention (1980) (the "Convention"), U.S. Co. is considered to be a resident, for purposes of the Convention, of the U.S. only. ... However, since a deemed disposition under section 48 of the Act is considered to be an alienation of property for the purposes of the Convention, paragraph 4 of Article XIII of the Convention would exempt U.S. ...

This new position is applicable to Conventions in force as of March 28, 2002 and subsequent Conventions that come into force after that date. However, those responses also noted that, for the purposes of Canada's Income Tax Conventions, any payment for computer software will still be a royalty and subject to Article 12 where the definition of "royalty" in a particular Convention refers to "other intangible property". ... Convention. After March 27, 2002 a payment for the use of custom computer software will only be subject to the Royalty Article of a particular Convention if there is a reference to other intangible property in the royalty definition and there is no specific exclusion in the Royalty Article for computer software. ...

These sections of the Act are subject to the provisions of tax conventions between Canada and other countries. 1. ... Under article 18 of the Canada- Switzerland Tax Convention ("Convention") regarding the taxability of pensions, the term "pension" does not include payments made under the social security legislation of a Contracting State. ... Therefore, the Convention does not apply to exempt these types of payments from taxation in Canada. ...

Is such a royalty also exempt from withholding tax under paragraph 3(a) of Article XII of the Canada-US Income Tax Convention? ... Such payments would also be a royalty referred to in paragraph 3(a) of Article XII of the Convention and be exempt from withholding tax under that Convention. ... Nor would such amounts be a royalty referred to in paragraph 3(a) of Article XII of the Convention. ...

Principal Issues: Whether the U.S. charitable organization can be considered to be a qualified donee for purposes of section 149.1 of the Act pursuant to Article XXI(6) of the Canada-United States Income Tax Convention (the "Convention") Position: No Reasons: Article XXI(6) of the Convention merely treaty gifts to U.S. charities as gifts to Canadian registered charities if certain conditions are met. ... Leung Attention: XXXXXXXXXX February 27, 1998 Dear Sirs: Re: Article XXI(6) of the Canada-United States Income Tax Convention (the "Convention") We are writing in response to your letter of October 17, 1997 in which you requested our interpretation of Article XXI(6) of the Convention with respect to the following hypothetical fact situation. ... Furthermore, relief is only provided under paragraph 6 of Article XXI of the Convention to a resident of Canada who has U.S. source income in the year a gift was made by the resident to a U.S. organization. ...

Est-ce que l'expression «convention écrite» inclus convention entre actionnaires qui prévoit choix entre rachat des actions par la société ou achat des actions par les actionnaires survivants? ... Une convention entre actionnaires est généralement considérée aux fins de ce type de clause transitoire une convention écrite si la convention entre actionnaires prévoit toutes les clauses nécessaires (y compris le critère de fixation du prix d'achat des actions) à la disposition des actions d'une société par la succession d'un actionnaire décédé en faveur de la société ou des actionnaires survivants. ... En ce qui concerne votre question sur la signature d'une convention entre l'actionnaire unique d'une société et cette société, nous ne sommes pas en mesure de faire des commentaires sans connaître le contenu de la convention reliée à la liquidation de la société et les procédures suivies pour que la liquidation se conforme à la loi sur les sociétés applicable à la société. ...

Subject to any relief provided in the Convention, the UK may also tax a Canadian resident on income from sources in the UK. ... Once the income of a taxpayer is determined under the Act, he can then turn to the provisions of the Convention for a relief. ... In your example, the FTC provisions of the Convention do not enhance the FTCs that are already provided in the Act. ...