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As permitted by the Convention, Revenue Canada, Taxation has entered into an arrangement with the Federal Tax Administration of Switzerland whereby we periodically provide them with copies of NR4 and NR4-A slips that show amounts paid to persons with Swiss addresses.  We are of the opinion that the Convention authorizes our department to provide this information to the Swiss authorities in the manner presently being exercise. However, where the interest and dividends are remitted directly to a Lienchtenstein beneficial owner, the Convention would not apply (i.e. we would not provide the Swiss with a copy of the NR4). ...

30 April 1985 Income Tax Severed Letter 0-230 F RE: Delay Rentals Paid to Non-Residents As a result of the recent ratification of the Canada-United States Income Tax Convention, 1980, ("the 1980 Convention"), we are reviewing our present treatment of delay rentals paid to non-residents. ... Because Article VI of the 1980 Convention now permits us to tax U. S. Recipients of such amounts under Part 1 or Part XIII (compare Article VIII of 1942 Convention- Part XIII route only available), we are in a position, if we desire and it is practical to do so, to introduce consistent Part I taxation of these amounts after 1985 for both residents and non-residents. ...

Ltd. would be considered to be a resident of the United States for the purposes of the Canada-United States Income Tax Convention and a resident of the United Kingdom for the purposes of the Canada-United Kingdom Income Tax Convention. ... Ltd. would have a wholly-owned Canadian subsidiary (Canco) which would pay dividends and have other dealings with its non-resident parent company to which the provisions of both Conventions might be applicable. We agree with your suggestion that the companies should be free to choose which of the two Conventions should apply in such cases. ...

Harding XXXX Dear Sirs: This is in reply to your letter of September 18, 1984, concerning Article XXX of the Canada-United States Income Tax Convention (Convention). ... However, since paragraph 6 of Article X of the Convention limits the rate of additional tax to 10 per cent of branch earnings, we are of the view that the requirement of subparagraph 11(4)(a) has not been met and, accordingly, the branch tax will not be reduced to 10 per cent prior to the period set out in paragraph 2(b) of Article XXX of the Convention. ...

We have reviewed the Canada-Australia Income Tax Convention, and it is our view the Australian payers are withholding the appropriate rate of tax on dividend and interest based on the information submitted. The Canada-Australian Income Tax Convention does not provide an exemption for dividends and interest received by pension fund trusts similar to Article XXI of the Canada-United States Income Tax Convention. ... You may wish to review the Australian Income Tax Act or contact the Australian authorities to determine whether they have exceptions to the general rule set out in the Canada-Australia Income Tax Convention. ...

Income Tax Convention (1980) (the "Convention") and to delete therefrom the portion reported as interest. ... It is our position that for purposes of the Convention, amounts received out of an IRA will be a payment from a retirement plan and as such fall within Article 18 of the Convention. ...

Convention (1978) has been brought to the attention of P & I by XXXX The Problem involves a Canadian corporation borrowing Canadian dollars from a United Kingdom lender. ... Convention and because paragraph 7 of Article XI of this Convention operates to deem the interest to arise in the U.K., the interest paid is not only subject to tax in Canada, but at a 25% rate rather than the 15% rate applicable to interest arising in Canada. ... Convention XXI " " " XI- paragraph 7 of OECD model XXI ...

Harding XXXX This is in reply to your letter of October 4, 1984, concerning the Canada-United Income Tax Convention (Convention). The Department of Finance Release dated August 16, 1984, a copy of which is attached, clearly indicates that the technical explanation under date of April 26, 1984, issued by the United States Treasury Department accurately reflects the understandings reached with respect to the interpretation and application of the various provisions of the Convention. ... Since the term pension is defined for the purposes of the Convention, it is our position that the reference to "retirement" benefits in paragraph 2(a) of Article XXI should not be restricted to employees and this appears to be in line with the view expressed in the technical explanation. ...

Donnelly XXXX Dear Sirs: Re: Canada-United Kingdom Income Tax Convention (1978) This is in reply to your letter of April 6, 1981 concerning Articles 27(4), 10(3) and 28(4) of the above Convention. ... Further to your telephone request, it is our view that the tax credit referred to in Article 10(3)(b) of the Convention would be income for Canadian tax purposes in the year the dividend itself is paid. ... Hartwick Assessing Division (O A-1240-1) KJD/jb O.P.R.U.- Canada-United Kingdom Convention Articles 10, 27 and 28 ...

Income Tax Convention (1980) (the "Convention") and to delete therefrom the portion reported as interest. ... It is our position that for purposes of the Convention, amounts received out of an IRA will be a payment from a retirement plan, and as such fall within Article 18 of the Convention. ...