Search - convention

Séguin (613) 957-8953 A l'attention de XXXXXXXXXX Le 6 septembre 1995, Monsieur, La présente est en réponse à votre lettre du 15 mars 1995 dans laquelle vous demandez notre opinion concernant la Convention fiscale entre le Canada et la Suisse (la "Convention"). ... Le revenu de salaire de source Suisse est imposable, sous réserve du paragraphe 2 de l'article XV de la Convention, en Suisse en vertu de l'article XV de la Convention. ... Nous tenons à noter que l'article XVII de la Convention ne nous apparaît pas pertinent dans les circonstances. ...

Co. est-il imposable en vertu de la Convention? Vos prétentions Votre position est de considérer le gain en capital réalisé par U.S. Co. comme étant imposable au Canada en vertu de la disposition XIII (3)(b)(ii) de la Convention. 24(1) Prétentions de U.S. ... La disposition XIII(3)(b)(ii) de la Convention réfère à la notion de biens immeubles.  ...

Income Tax Convention- U.S. Subsidiaries of Canadian Bank not Dealing at Arm's Length 19(1) 7-4062 K.B. ... Income Tax Convention (Convention) This is to outline the Department's views concerning the withholding of Part XIII tax in the following hypothetical situation. ... It should be noted that such an exemption is applicable to this particular Convention and its application to other income tax conventions or agreements may not produce the same result. ...

Your question Does Article XIII of the Convention exempt the total capital gain from taxation in Canada? Our views The definition of taxes covered in subparagraph 2(a) of Article II of the Convention indicates that in the case of Canada the existing taxes to which the Convention shall apply include those levied under Part I of the Act.  As minimum tax is levied under Part I of the Act it is covered by the Convention. ...

7 July 1991 Income Tax Severed Letter- Meaning of the term “profits of an enterprise of one of the Contracting States” as used in Article III of the Canada-Japan Income Tax Convention Unedited CRA Tags Canada–Japan Income Tax Convention article III, II Re: Canada-Japan Income Tax Convention, 1965 (the "Convention")-Capital Gains This is in reply to your letter dated May 7, 1991 whereby you requested our opinion as to the meaning of the term "profits of an enterprise of one of the Contracting States" as used in Article III of the Convention. ... In interpreting the Convention it is of course necessary to have regard to the meaning, as set forth in the Convention, of terms specifically defined therein. ... Therefore, we consider the "profits" referred to in Article III of the Convention to be profits from carrying on a business, i.e. business income. ...

Income Tax Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Income Tax Convention (1980) (the "Convention") permits an extension of the October 1, 1984 date up to the end of the first taxation year of the recipient beginning after 1985. ... Income Tax Convention. We trust these comments will be of assistance to you. ...

27 February 1990 Income Tax Severed Letter AC57484- Canada-Australia Income Tax Convention on Residence Unedited CRA Tags none 5- 7484 19(1) R.C. O'Byrne (613) 957-2126 February 27, 1990 Dear Sirs: Re: Article 4 Canada-Australia Income Tax Convention (the “Convention”) This is in reply to your letter of January 30, 1989 in which you asked whether an Australian Non-Profit Society (a “Society”) would be considered a resident of Australia for purposes of the Convention. ... Accordingly, we are of the view that Article 4(2) of the Convention would not preclude a Society from being considered resident in Australia for purposes of the Convention. ...

7 December 1991 Income Tax Severed Letter- Rents from movable property and the Canada-Norway Income Tax Convention Unedited CRA Tags Canada-Norway Income Tax Convention Rents from Movable Property Canada-Norway Income Tax Convention (the "Convention") This will follow up a telephone conversation with Mr. ... Generally, all amounts received by a resident of Norway from a resident of Canada would be included in the profits of the enterprise of the Norwegian resident for the purposes of Article 6 (Business Profits) of the Convention unless such amounts are carved out by another article of the Convention. Since the definition of royalties in Article 11 (Royalties) of the Convention does not include bareboat rents paid or credited by a resident of Canada to a resident of Norway such amounts will fall within Article 6 (Business Profits) of the Convention and will be exempt from tax in Canada unless the Norwegian resident carries on business in Canada through a permanent establishment. ...

Income Tax Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Income Tax Convention (the "U.S. Convention"). Generally, for purposes of the U.S. Convention, it is our view that a U.S. partnership is not a resident of a Contracting State. ...

Income Tax Convention Art. 13 Dear Sirs: Re: Article 13(9) of the Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter dated June 5, 1991 whereby you requested our views concerning the meaning of the phrase "a resident of that State for 15 years or more" in the context of the application by Canada of subparagraph 9(a) of Article 13 of the Convention. In our opinion, in order for an individual to have been a resident of Canada for 15 years or more for purposes of subparagraph 9(a) of Article 13 of the Convention, the individual must have been a resident of Canada (as defined for purposes of the Convention) at least for 15 periods (not necessarily consecutive) each of which consists of 12 consecutive months. ... Such a deeming provision will be taken into account in determining whether an individual has been a resident of Canada for 15 years or more for purposes of subparagraph 9(a) of Article 13 of the Convention. ...