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In addition, if a joint venture would be considered to have a permanent establishment in Canada for the purposes of an income tax convention that Canada has with another country, it if were a resident of a contracting state for the purposes of that convention, any member of such a joint venture who is resident in that country will generally be considered to have a permanent establishment in Canada. ...

It is essentially a question of fact, having regard to the definition in the applicable income tax convention or, if there is no applicable convention, Regulation 400(2), as to whether as a corporation has a permanent establishment in respect of its international shipping business in the country in which it is resident. ...

23 November 1992 Income Tax Severed Letter 9221815- A société en nom collectif is a partnership Unedited CRA Tags 96(1), 126, 20(12), Canada–France Income Tax Convention Article 3 922181 24(1) G. ... With respect to the application of the Act and the Canada-France Income Tax Convention (1975) for such a partner, the SNC is neither a resident nor an enterprise of France. ...

Selon le paragraphe 215(1) de la Loi une personne qui verse ou crédite ou est réputée avoir versé ou crédité une telle somme (celle sujette aux dispositions de l'article 212 de la Loi) doit, nonobstant toute disposition contraire d'une convention ou d'une loi, en déduire ou en retenir le montant de l'impôt sur le revenu et le remettre immédiatement au receveur général au nom de la personne non résidante et l'accompagner d'un état selon le formulaire prescrit. En vertu de l'article XII de la Convention fiscale entre le Canada et les États-Unis, la somme à retenir en vertu du paragraphe 215(1) de la Loi à l'égard de logiciels est réduite de 25% à 10%. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII, XXIV 921629 XXXXXXXXXX Olli Laurikainen (613)957-2116 Attention: XXXXXXXXXX January 20, 1993 Dear Sirs: Re: Subsection 126(1) of the Income Tax Act (the "Act") This is in reply to your letter of May 11, 1992 wherein you requested a technical interpretation regarding subsection 126(1) of the Act and the Canada- U.S. Income Tax Convention (1980) (the "Treaty") in the following hypothetical situation: 1. ...

Income Tax Convention Art. 17 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 (Treaty) and of the Income Tax Act (Act) to residents of the United Kingdom(U.K.) ...

Accordingly, the above payments by Company C to Company A, which otherwise would, in the case, of a non-treaty country, be subject to withholding tax pursuant to subsection 212(5) of the Income Tax Act, are exempted from tax by Article I of the Canada-United States Tax Convention because they are payments on account of industrial and commercial profits of a U.S. resident. XXX XXX such a payment would represent a royalty or similar payment on or in respect of a copy right and would be exempt from non-resident withholding tax by virtue of subparagraph 212(1)(d)(vi) of the Income Tax Act as well as by Article XIII C of the Canada-United States Tax Convention, assuming with regard to the latter that all the provisions of that Article are otherwise met. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI 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 (the "Treaty"). In the situation you describe, a corporation (A Co.), which is a resident of Canada for the purposes of the Treaty, carried on business in the U.K. through a permanent establishment therein. ...

Income Tax Convention Art. XVII Further to our telephone conversation, we are forwarding XXX letter of October 23, 1987 together with a copy of our reply dated January 19, 1988. XXX In computing the amount of pension income subject to tax in XXX pursuant to paragraph 212(1)(h) of the Income Tax Act, a deduction of $10,000 was properly allowed by Jonquiere in accordance with Article XVII of the Canada-United Kingdom Income Tax Convention (1978) ("former Article XVII"). ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII 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) (the "Treaty"), the reduction described therein would not apply. ...