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Tax Convention Canada-U.S. Tax Treaty:Art. 11 This is in reply to your letter of May 20, 1986 concerning whether interest payments by certain Canadian institutions on debt obligations owing to residents of the United Kingdom (the "U.K. ... Income Tax Convention also exempts from the withholding tax rules, interest arising in Canada and paid to a resident of the U.K. if it is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by the United Kingdom Export Credit Guarantee Department. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Dear Sirs: This is in reply to your letter dated June 8, 1989. ... Income Tax Convention (1980). It is our understanding that in most cases this Canadian tax is creditable against U.S. income taxes. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII, Canada--Japan Tax Treaty article VIII 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. ... Tax Convention since such payment is not subject to the withholding tax under the Canadian income tax law. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI This is in reply to your letter of May 21 concerning interest being paid by a Canadian bank to your grandmother, a U.S. resident and citizen. ... Income Tax Convention (1980), the rate of Canadian Part XIII tax on interest paid to a resident of the U.S. is 15%. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Dear Sirs: This is in reply to your memorandum of July 12, 1989 wherein you requested information concerning the tax treatment of payments made to a U.S. resident with respect to software purchases by a resident of Canada. ... Income Tax Convention reduces the withholding rate to 10 per cent where the use payments are made to a resident of the United States. ...

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. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VII Dear Sirs: This is in reply to your letter dated February 1, 1988 wherein you requested our opinion on the tax consequences of a sale by a United States resident of a trade mark and design mark registered in Canada. ... Therefore, if the United States resident has a permanent establishment in Canada, he could be subject to tax on that income pursuant to section 14 of the Act and Article VII of the Canada-United States Income Tax Convention (1980). ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Subject: Copyright Royalties and Cable Company Retransmissions This is in reply to your memorandum of October 30, 1990 wherein you requested we review the opinion expressed therein with respect to the treatment of payments to be made by cable companies and other retransmitters to U.S. residents for the right to retransmit distant television and radio signals. ... Income Tax Convention permits Canada to tax such royalty payments made to U.S. residents, however, the rate of withholding tax on such payments is limited to 10% of the gross amount of the royalty payments. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Dear Sir: Re: Disability Payments made to Non-Resident This is in reply to your letter dated March 19, 1991 whereby you requested our opinion in respect of the following hypothetical fact situation: Facts If the taxpayer had remained resident in Canada, the payments in question would have been taxable under paragraph 6(1)(f). ... By virtue of subparagraph 2(a) of Article XVIII of the Canada-United States Income Tax Convention, 1980, the tax that Canada may impose on the payments here in question will be limited to an amount not in excess of 15 percent of the gross amount of such payments provided the plan qualifies as a pension as defined in paragraph 3 of that Article. ...

7 April 1991 Income Tax Severed Letter- Correspondance of France Pension Plan a Pension Plan Recognized for Canadian Tax Purposes Unedited CRA Tags 6(1)(a), Canada-France Tax Convention (1975) Article 29 Dear Sirs: Re: Our letter of April 4, 1991 Further to the above-noted letter and our telephone conversation of April 15, 1991, this is to advise that Article 29 of the Canada-France Tax Convention (1975) contains a provision which may be applicable to the situation on which you asked us to comment. ...