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31 January 1990 Internal T.I. 90M01157 F - Canada-United Kingdom Income Tax Convention

31 January 1990 Internal T.I. 90M01157 F- Canada-United Kingdom Income Tax Convention Unedited CRA Tags 116 19(1) E.E. Campbell (613) 957-2067 January 31, 1990 Dear 19(1) Re: Canada-United Kingdom Income Tax Convention Articles 26 and 27, Section 116 of the Income Tax Act On February 22, 1989, we wrote to you concerning a problem involving residency and domicile. ...

11 April 1990 Internal T.I. F2857 F - Non-arm's Length Sales of Shares by Non-residents - Canada-U.S. Income Tax Convention

Income Tax Convention Unedited CRA Tags 212.1 April 11, 1990 Director General Current Amendments and Specialty Rulings Directorate Regulations Division D.W. ... Convention Your memorandum (prepared by R.C. O'Byrne) dated March 14, 1989 was sent to Finance for their comments. ...

18 January 1990 External T.I. 74445 F - Part I.1 Surtax for 1985 - Application of Canada-Germany Income Tax Convention

18 January 1990 External T.I. 74445 F- Part I.1 Surtax for 1985- Application of Canada-Germany Income Tax Convention Unedited CRA Tags n/a January 18, 1990 Scarborough District Office Specialty Rulings Directorate J.E. ... Baronette (613) 957-2109 Director File No. 7-4445 Subject: 19(1) Part I.1 surtax for 1985 Application of Article 23 of the Canada-Germany Income Tax Convention Further to our memorandum to the Toronto District Office dated September 11, 1989 (forwarded to your office on October 2, 1989) and to the memorandum dated October 20, 1989 from Mr. ...

17 September 2007 External T.I. 2007-0250101E5 - Article 12(4) of Canada/Switzerland Tax Convention

17 September 2007 External T.I. 2007-0250101E5- Article 12(4) of Canada/Switzerland Tax Convention Principal Issues: Whether an aircraft would be considered to be equipment for the purposes of Article 12(4) of the Canada-Switzerland Tax Convention. ... Zhang (613) 957-2104 September 17, 2007 Dear XXXXXXXXXX: Re: Article 12(4) of the Canada-Switzerland Tax Convention We are writing in response to your letter of August 16, 2007 in which you requested our comments regarding the tax treatment of payments for the use of an aircraft under the Canada-Switzerland Tax Convention (the "Treaty"). ...

30 August 1990 Ministerial Correspondence 900414 F - Canada-U.S. Income Tax Convention on Canadian Tax and Filing Obligations

Income Tax Convention on Canadian Tax and Filing Obligations Unedited CRA Tags 69(3), 150(1), 150(2), 115 24(1) 900414 G. Arsenault (613) 957-2126 Attention: 19(1) EACC9245 August 30, 1990 Dear Sirs: Re: Canadian Tax and Filing Obligations U.S.- Canada Tax Convention This is in reply to your letter dated March 20, 1990 to the Non-Resident Taxation Division. ... In particular we note that the Commentary on the Model Double Taxation Convention on Income and Capital in the Report of the OECD Committee on Fiscal Affairs, 1977 is consistent with the view that USCo has a permanent establishment in Canada. ...

31 January 1990 Ruling HBW6591G1 F - Canada-Germany Income Tax Convention

31 January 1990 Ruling HBW6591G1 F- Canada-Germany Income Tax Convention Unedited CRA Tags n/a 19(1) David R. Senécal (613) 957-2074 HBW 6591-G1 HBW 4125-G1 January 31,1990 Mr. 19(1) Re: Exchange of Information under the Canada-Germany Income Tax Convention (1956) 19(1) Following your request dated November 14, 1989, we have attempted to obtain the information required. ...

5 February 1990 Internal T.I. 90M02427 F - Competent Authority Request under Canada-Finland Tax Convention

5 February 1990 Internal T.I. 90M02427 F- Competent Authority Request under Canada-Finland Tax Convention Unedited CRA Tags n/a TELEX MESSAGE Originator: B. FIORAVANTI Date: 5/02/90 Branch: LEGISLATION Building: MACDONALD Room Number: 1000 Telephone Number: 957-2073 Other Destination: FINLAND 123241 FIMIN SFAttention: 19(1) File No. 90M02427 Message: RE: 19(1) COMPETENT AUTHORITY REQUEST UNDER CANADA- FINLAND TAX CONVENTION OUR INTERNATIONAL AUDITS DIVISION HAS WRITTEN TO YOU ON APRIL 14, 1988, AND FURTHER ON NOVEMBER 2, 1988, AND JUNE 1, 1989. ...

28 September 1989 External T.I. ACC 8675 F - Canada-France Income Tax Convention on Pensions

ACC 8675 F- Canada-France Income Tax Convention on Pensions Unedited CRA Tags n/a September 28, 1989 S. ... Senécal 957-2074 HBW 4125-F1 19(1) Paragraph 5 Article XXIX Canada-France Income Tax Convention As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada. ...

12 October 1989 Income Tax Severed Letter ACC8587 F - Canada-France Tax Convention

12 October 1989 Income Tax Severed Letter ACC8587 F- Canada-France Tax Convention Unedited CRA Tags n/a October 12, 1989 S. ... Pettifer 957-2072 HBW 4125-F1 24(1) PARAGRAPH 5, ARTICLE XXIX CANADA-FRANCE INCOME TAX CONVENTION As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada. ...

16 June 1991 External T.I. 9113055 F - Canada-Italy Income Tax Convention

16 June 1991 External T.I. 9113055 F- Canada-Italy Income Tax Convention Unedited CRA Tags 2(1), 126(1), 126(7) non-business income tax, Treaty Italy 5-911305 Dear Sirs: Re: Canada-Italy Income Tax Convention This is in reply to your letter of May 7, 1991 wherein you requested our views on the income tax liabilities of a Canadian resident in the following hypothetical situation as outlined in your letter. ... X is employed in Italy by an employer that does not have a permanent establishment (within the meaning of Article V of the Canada-Italy Income Tax Convention Act,1980 (the "Tax Treaty") or other fixed base in Canada. 3. ...

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