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Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information Where the beneficial owner of the interest is a resident of Belgium under the Canada-Belgium Income Tax Convention, or a resident of the Netherlands under the Canada-Netherlands Income Tax Convention, the tax so charged shall not exceed 15% of the gross amount of the interest. ...

6 May 1986 Income Tax Severed Letter 5-1045 Unedited CRA Tags 212(1)(d), Canada-Norway Income Tax Convention article II 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. ... Dear XXX This is in reply to your letter of February 13, 1986 in which you request our opinion on whether Article II of the Canada-Norway Income Tax Convention (the "treaty") exempts residents of Norway from Canadian tax in respect of rental income from moveable property. ...

Income Tax Convention Art. XII 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 (1978). In response to your concern about the possibility of double taxation, we agree that this may result. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII 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. ... Income Tax Convention (1980). Hence, the Canadian payor is obligated, pursuant to subsection 215(1) of the Income Tax Act, to withhold the applicable 10% rate of tax and remit same to the Receiver General by the 15th day of the month following the month in which the tax was withheld. ...

16 March 1988 Income Tax Severed Letter 5-3872 Unedited CRA Tags Canada-Netherlands Income Tax Convention articles 4 and 10 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. ... Dear Sirs: This is in reply to your letter of September 11, 1987 in which you requested our opinion on interpreting Articles 4 and 10 of the Canada-Netherlands Income Tax Convention (1986) (the "Treaty") as they apply to a Dutch pension fund which is exempt from income tax in the Netherlands under the Dutch income tax act. ...

Tax Convention This is in reply to your memorandum of December 17, 1981 concerning a U.K. resident beneficiary of a Canadian trust or estate. ... Convention would dictate that we refund the additional 10% that was withheld in 1982. ...

These funds are presently retained by us and in discussions with Kevin Donnelly, who is with the rulings Division of the Income Tax Department in Ottawa, we reviewed with him the possibility of obtaining some clarification of the effect of Article XIII, para- graph 4(a) of the Tax Convention with the United Kingdom on our client's transaction. ... It is our understanding that the Convention article above referred to is intended to tax those gains from the sale of shares of companies who are primarily in the real estate investment business or whose assets are primarily real estate. ...

Tax Convention (1978), hereinafter referred to as the Treaty specifically, Article XV. ... Tax Convention. This technical interpretation indicates that borne means "... allowable as a deduction in computing taxable income". ...

We are guided by the draft double taxation convention on income and capital that has been prepared by the Organization For Economic Co-operation and Development, a body in which Canada is a member. ... Agreement is reasonably parallel to paragraph 1 of Article 14 of the OEM model conventions the OECD commentary on Article 14(1) should be a relevant guide. ...

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. ...