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7 July 1991 Income Tax Severed Letter- Canada-United Kingdom Income Tax Convention article 27(2) Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 27 Dear Sirs: Re: Article 27(2) of the Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter dated June 28, 1991. In our opinion, paragraph 2 of Article 27 of the Convention not only applies to restrict the application of provisions of the Convention pursuant to which income is totally exempted from taxation but also applies to restrict the application of provisions of the Convention, such as paragraph 1 of Article 20, pursuant to which the amount of tax a Contracting State may impose is limited (but not absolutely eliminated). ...

Income Tax Convention- U.S. Estate Tax Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... II, XXIII, OECD Model Double Taxation Convention on Income and Capital, Art. 22 Re: Canada-United States Income Tax Convention, 1980 (the “Convention”)- U.S. ... It is our understanding that United States estate tax is not a tax on capital and that Article XXIII of the Convention is not applicable thereto. ...

Income Tax Convention] XXXX T.B. Kuss (613) 957-2117 February 2, 1988 Dear Sirs: Re: Article X, Paragraph 6 of the 1980 Canada-U.S. Income Tax Convention (the "Convention") This is in reply to your letter dated December 1, 1987 in which you requested a technical interpretation of the above-referenced provisions of the Convention within the context of the following hypothetical situation. ... Opco is not and has not been associated (within the meaning of subparagraph 6(d) of Article X of the Convention) with another company nor has it previously deducted any amounts in respect of subparagraph 6(d) of Article X of the Convention. ...

Pertinence L'article 4 de la Convention établit le sens de "résident d'un État contractant" aux fins seules de la convention fiscale. ... Imnact de la Convention et de la résidence réputée La Convention peut réputer le particulier-type etre un non-résident du Canada aux fins de la Convention mais l'alinea 250(l)d) de la Loi demeure toujours pertinent. ... L'article 4 de la Convention établit les règles du jeu de la convention fiscale pour ses autres dispositions d'allégement. ...

Our Comments Article 13 sub-paragraph 4 (a) of the Convention stipulates that the capital gain realized on the sale of the shares can be taxed in Canada, whereas by virtue of Article XVII of the Canada-Netherlands Income Tax Agreement Act, 1957, (the “Former Convention”) such a gain would have been taxable only in the Netherlands. By virtue of paragraph 3 of Article 30 of the Convention, any provisions of the Former Convention that would have afforded any greater relief from tax shall continue to have effect for any taxation year beginning before the entry into force of the Convention. ... The Convention entered into force on August 21, 1987, and XXX chose August 1, 1987 as the beginning of its fiscal period. ...

7 October 1991 Income Tax Severed Letter- Shipping and Air Transport Provisions of the Canada-Netherlands Income Tax Convention Unedited CRA Tags Canada-Netherlands Income Tax Convention Dear Sirs: Re: Shipping and Air Transport Provisions of the Canada-Netherlands Income Tax Convention, 1986 (the "Netherlands Convention") This is in reply to your letter dated August 20, 1991. ... Dutchco is not a resident of Canada, is a resident of the Netherlands for Dutch tax purposes and is solely a resident of the Netherlands for purposes of the Netherlands Convention. ... We note that the summary of your understanding of the effect of the Netherlands Convention set forth in your letter of August 20, 1991 made no reference to Paragraph II of the Protocol to the Netherlands Convention. ...

7 August 1991 Income Tax Severed Letter- Canada-United States Income Tax Convention- Maintenance Payments Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XVIII(6) Dear Sirs: Re: Article XVIII(6) of the Canada-United States Income Tax Convention, 1980 This is in reply to your letter dated May 8, 1991 concerning the application of Article XVIII(6) of the Canada-United States Income Tax Convention, 1980 (the "Convention") in the following hypothetical fact situation: 1. ... The Technical Explanation issued by the United States on the Convention provides additional comments on this matter. ...

Income Tax Convention (the "Convention") This is in reply to your memorandum of October 19, 1989 concerning what is meant by the term "gain which is liable to tax in that other State" in paragraph 9 of Article XIII of the Convention. ... Article III of the Convention provides a definition of many terms used in the Convention, however, the article does not define the term "gain" for purposes of the Convention.  ... Since the Competent Authority of Canada has not agreed to the meaning of any term under subparagraph (d) of paragraph 3 of Article XXVI of the Convention and the term gain is not defined in the Convention, paragraph 2 of Article III of the Convention will apply. ...

7 October 1990 Income Tax Severed Letter- Capital gains and the Canada-Japan Income Tax Convention Unedited CRA Tags Canada–Japan Income Tax Convention Article 13 Dear Madam: Re: Canada-Japan Income Tax Convention (1986) (the "Convention") This is in reply to your letter dated August 3, 1990. In our opinion, residents of Japan are not granted any exemption from Canadian tax on capital gains by the Convention. Article 13 of the Convention does not purport to grant any such exemption and Article 20 applies only to income and does not apply to capital gains. ...

La convention prévoit aussi des droits de renouvellement (moyennant les frais chargés à ce moment pour la période de renouvellement) et des droits de cession. Vous nous demandez quel est le traitemnt fiscal pour la société découlant de l'acquisition des droits dans ladite convention. ... Il nous apparaît que les droits découlant de la convention procurent un avantage durable assimilable à un permis de durée limitée pour le consommateur signataire. ...