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Tel qu'énoncé lors du Congrès de 1995 de l'Association de planification fiscale et financière, nous vous confirmons que la position du Ministère concernant les conventions d'achat d'actions qui permettent à un employé de recevoir un paiement en espèces plutôt que des actions n'a pas changé. ... De plus, l'alinéa 7(3)b) n'empêche pas un employeur de déduire les sommes versées puisqu'aucune action n'a été vendue ou émise en vertu de la convention. ...

29 March 2004 External T.I. 2004-0054831E5- Treaty benefits for Luxembourg Investment Funds Principal Issues: Are FCPs, SICAVs and SICAFs eligible for the benefits of the Canada-Luxembourg Tax Convention? ... Cook March 29, 2004 Dear XXXXXXXXXX: Re: Canada-Luxembourg treaty benefits We are writing in reply to your letter dated December 18, 2003, which requested our opinion as to whether dividends and interest paid by Canadian corporations would be eligible for the reduced withholding tax rates provided by the Canada-Luxembourg Tax Convention (the "Treaty"). ...

Reasons: Not taxable in Hungary, therefore not taxable in Canada- see subparagraph 4(c) of Article 18 of the Canada-Hungary Tax Convention. ... Pursuant to subparagraph 4(c) of Article 18 of the Canada-Hungary Tax Convention, Canada cannot tax pensions and allowances paid under the social security legislation of Hungary and received by Canadian residents so long as the payments are not subject to tax in Hungary. ...

The Income Tax Convention between Canada and Finland (effective January 1, 1958) contains no provisions that exempt these particular sources (whether "pension" income or not under the treaty definitions) form tax in Canada.  ... The credit, pursuant to Article XIII of the Convention, cannot exceed the Canadian taxes attributable to those sources.  ...

Accordingly, the transfer of funds from the Canadian pension plan to the Australian pension plan under a reciprocal pension transfer agreement would be subject to the withholding tax which is reduced to 15% in accordance with article 18 of the Canada-Australia Tax Convention. Similarly, if the transfer agreement is not finalized and the taxpayer withdraws his own contributions to the Public Service Superannuation account while he is a resident of Australia, the payment of these funds would also be subject to paragraph 212(1)(h) withholding tax reduced to 15% pursuant to the Canada-Australia Tax Convention on any amount paid to the taxpayer as a payment of a superannuation or pension benefit. ...

Income Tax Convention (1980). With respect to your first query, it remains our opinion that notwithstanding the deeming provisions of the United States Internal Revenue Code., an "S" corporation for Canadian tax purposes is considered to be a corporation under U.S. corporate law and as such, absent any FAPI implications, a Canadian resident shareholder thereof is only subject to Canadian income tax on amounts received from or benefits conferred by the "S" corporation and is not subject to such tax on the undistributed earnings of that corporation. ... Income Tax Convention (1980). We trust that this information will be of assistance to you. ...

Arsenault (613) 957-2126 Attention: 19(1) AUG 15 1990 Dear Sirs: Re: Subsection 212(13.1) of the Income Tax Act and Article XI of the Canada-United States Income Tax Convention 1980 This is in reply to your letter dated March 15, 1990 whereby you requested our views as to the application of the above-noted provisions of the Income Tax Act and the Canada-United States Income Tax Convention, 1980 (the "Treaty") to interest paid by a partnership comprised entirely of U.S. resident individuals on a loan (not secured by real property situated in Canada or any interest therein) made by a U.S. bank to the partnership to finance the acquisition of Canadian rental property in respect of which the partners intend to make an election under section 216 of the Act. ...

Income Tax Convention Art. XI February 6, 1990 Mr. M.A. Hiltz Provincial and International Director Relations Division Re-Organizations and J. Wilson Non-Resident Division 957-2063 Attention: Ken Major EACC8732 Chief, Foreign Section 24(1)- SECURITY LENDING REVENUE CANADA- UNITED KINGDOM INCOME TAX CONVENTION We are writing in regard to an interpretation of Article XI, sub-paragraph 4(a) and paragraph 5 of the above-noted treaty. 24(1) has requested confirmation as to the tax treatment of income received by the 24(1) as compensation for Canadian Government Bonds loaned pursuant to a securities lending arrangement. 24(1) is of the opinion that the treaty exempts this income from Part XIII tax (copy of letter attached). ...

30 May 1990 Income Tax Severed Letter HBW 4125-F1 HBW 6591-F2 Unedited CRA Tags Canada-Finland Income Tax Convention HBW 4125-F1 HBW 6591-F2 Jim Wilson (613) 957-2063 May 30, 1990 Dear xxxxx Re: Finnish National Old Age Pension and Front Veterans Supplement We are writing in follow-up to our letter dated January 10, 1990 (copy attached), concerning the taxability in Canada of certain pension benefits received from Finland by a resident of Canada. ... The Finnish National Old Age Pension does not meet the definition of "pension" or "annuity" under Article II of the Canada-Finland Income Tax Convention (1958). ...

Income Tax Convention Art. 5, 33 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Toussaint Jim Wilson Director General 957-2123 Attention: John Fennelly 921078 Offshore Activities- xxx Canada-United Kingdom Income Tax Convention (the "treaty") This is in reply to your memorandum of April 6, 1992 in which you requested confirmation of our previous comments made in our memorandum of July 12, 1991 regarding Article XXVIIA of the treaty. ...