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De manière plus précise et aux termes d'une convention par écrit (ci-après la " Convention "), OPCO " concèderait " à une personne (ci-après l' " Acheteur ") un habitacle ou une crypte dans un columbarium ou mausolée et ce, pour servir exclusivement de sépulture. Vous nous avez fourni un exemplaire de la Convention type qui serait utilisé dans les circonstances. ... OPCO contracterait par ailleurs les engagements suivants aux termes de la Convention. ...

Convention on the Taxation of Income and Capital (the "Convention") grants Canada the exclusive right to tax benefits under the social security legislation in the U.S. received by a resident of Canada. ... Where paragraph 5 of Article XVIII of the Convention applies, paragraph 110(1)(h) of the Act may provide an additional deduction from taxable income for individuals in receipt of benefits under the social security legislation in the U.S. ... 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. ...

Section 3 of the Inter-American Development Bank Privileges and Immunities Order (footnote 2) (the "IDB Order") indicates that the Organization, IDB, shall be entitled to certain privileges and immunities that are set forth in the Articles of the Convention on the Privileges and Immunities of the United Nations (footnote 3) (the "UN Convention") as follows: 3. (1) The Organization shall have in Canada the legal capacities of a body corporate and shall, to such extent as may be required for the performance of its functions, have the privileges and immunities set forth in Articles II and III of the Convention. (2) Representatives of states and governments that are Members of the Organization shall have in Canada, to such extent as may be required for the performance of their functions, the privileges and immunities set forth in Article IV of the Convention for representatives of Members. (3) Officials of the Organizations shall have in Canada, to such extent as may be required for the performance of their functions, the privileges and immunities set forth in Article V of the Convention for officials of the United Nations. (4) Experts performing missions for the Organization shall have in Canada, to such extent as may be required for the performance of their functions, the privileges and immunities set forth in Article VI of the Convention for experts on missions for the United Nations. ... X and potentially provide the privileges and immunities set forth in Article V of the UN Convention for officials of the United Nations. Paragraph (b) of Section 18 of Article V of the UN Convention provides that officials are "exempt from taxation on the salaries and emoluments paid to them". ...

D et OPCO ont conclu une convention unanime entre actionnaires (" Convention ") au cours de l'année 2004, laquelle est toujours en vigueur. ... Pour tel cas, le prix des actions à vendre sera le prix fixé à l'annexe de la présente convention. ... Votre question Est-ce que la clause de la Convention décrite au paragraphe 7 ci-dessus constitue un droit visé par le paragraphe 256(1.4) qui aurait pour effet de rendre OPCO associée à ACO, BCO, CCO et DCO? ...

Income Tax Convention (the "Convention"). You have presented a hypothetical situation where a Canadian resident company (Canco) obtains master videotapes or 35mm prints from a US company (USco). ... The expansion of the exemption to private home use, in particular as it relates to motion pictures, is unique to the Convention and can not be extended to other treaties. ... In respect of your references to subparagraph 3(d) of Article XII of the Convention as amended by the 1995 Protocol to the Convention, we note that that subparagraph has no impact on the above position. ...

2 July 2010 External T.I. 2007-0248991E5- Lump Sum Pension Payment Unedited CRA Tags Paragraph 212(1)(h) of the Act; Article XVIII of the Canada-US Tax Convention; Section 5 of the Income Tax Conventions Interpretation Act Principal Issues: Whether a payment under a RRIF to a non-resident can be bifurcated into a periodic pension payment and a lump sum payment Position: No apportionment allowed Reasons: Definition of "periodic pension payment" in the Income Tax Conventions Interpretation Act XXXXXXXXXX 2007-024899 Ross Kauffman July 2, 2010 Dear XXXXXXXXXX: Re: Lump Sum Pension Payment In your email, you asked us whether we would consider a portion of a lump sum payment under a registered retirement income fund to be a periodic pension payment that is eligible to be taxed at the 15% withholding rate in subparagraph 2(a) of Article XVIII of the Canada-U.S. Tax Convention (Treaty) rather than the 25% rate applicable to a lump sum pension payment. The portion you are suggesting that would be subject to the 15% rate is the amount determined under subparagraphs (c)(i) and (ii) of the definition of "periodic pension payment" in section 5 of the Income Tax Conventions Interpretation Act (ITCIA). ...

28 January 2008 External T.I. 2005-0144621E5- Qualified subchapter S subsidiary Unedited CRA Tags Article IV Tax Convention Principal Issues: Whether a qualified subchapter S subsidiary (QSSS) is a resident of the U.S. for the purpose of paragraph 1 of Article IV of the Canada-United-States Income Tax Convention? ... XXXXXXXXXX 2005-014462 Sylvie Labarre, CA January 28, 2008 Dear Sir: Re: Qualified subchapter S subsidiary This is in reply to your letter of July 20, 2005 in which you requested our views on whether a qualified subchapter S subsidiary (QSSS) is resident of the United States for purpose of paragraph 1 of Article IV of the Canada-United States Income Tax Convention (1980) (the "Convention"). ... Our view that an S corporation may be a person resident in the U.S. for the purpose of paragraph 1 of Article IV of the Convention remains unchanged. ...

Income Tax Convention (the "Convention") under Article IV thereof, for the reason that such LLC is not subject to tax in the United States. As a result, such LLC does not qualify for any of the benefits that are available to a person who is a resident of the United States for the purposes of the Convention. ... This being the case, at this time the Department has no basis on which to look through to the residency of such persons for the purposes of providing relief under an income tax convention. ...

Convention? Position: Yes. Reasons: Transfer under subsection 107(2) is a non-recognition transaction for Canadian tax purposes. 970898 XXXXXXXXXX J. ... Income Tax Convention (the "Convention"). You have asked if the benefits of paragraph 9 of Article XIII of the Convention would be available to a U.S. resident who disposes of Canadian real property where the property was originally owned by a Canadian resident trust which distributes the property to the beneficiaries. ... It is our view that, as the transfer under subsection 107(2) of the Act is a non-recognition transaction for Canadian tax purposes, the U.S. resident would be entitled to the benefit of the transitional rules in paragraph 9 of Article XIII of the Convention on the disposition of the real property. ...

That division took the position that any employment income earned outside the Jet Programme by a continuing resident of Canada, including further employment with the Japanese government as a teacher, is subject to income tax in Canada pursuant to Article 15 of the Convention. Participants in the Jet Programme are governed by Article 18 of the Convention and are exempt from tax in Canada based on the unique nature of the Programme. ... It is the initiative of and the employment by the Japanese government together with the additional responsibilities of the participants of the JET Programme which bring the participants from Canada into Article 18 of the Convention. ...