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Income Tax Convention (1980)] DATE: February 20, 1986 TO-A DATE: PROVINCIAL AND INTERNATIONAL RELATIONS DIVISION FROM-DE HEAD OFFICE Assessing Division ATTENTION R. ... Income Tax Convention (1980) We are writing to request clarification of Article XIX of the Canada-United States Income Tax Convention (1980) as it applies to employees of the U.S. ... Article XIX of the 1980 Convention no longer includes a reference to "any agency" of the United States. ...

Income Tax Convention (1980) (the "Convention") on January 1, 1986, the interest paid on these advances would have been exempt pursuant to the paragraph 2 of Article XII of the former 1942 Canada-U.S. ... Issue Paragraph 3(e) of Article XI of the Convention provides an exemption for interest paid with respect to an obligation entered into before the date of the Convention (i.e. September 26, 1980), provided that such interest would have been exempt under Article XII of the 1942 Convention. ...

Raisons POUR POSITION ADOPTÉE: Les paiements sont exemptés en vertu de la convention fiscale Canada- France. / The payments are exempt by virtue of the dispositions of the Canada- France Tax Convention. ... Question Vous nous demandez si, dans la situation précitée, nous partageons votre interprétation de la Loi et de la Convention. ... Ces paiements seraient plutôt visés par l'article 7 de la Convention qui traite des bénéfices des entreprises. ...

Income Tax Convention- Exemption Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Income Tax Convention ("Convention") Enclosed, for your information and use, are copies of our recent correspondence with 19(1) of the legal firm 24(1) in Montreal concerning 19(1) claim for an exemption from Canadian income tax under the Convention. ...

7 July 1990 Income Tax Severed Letter- Deductibility of expenses relating to a convention to be held aboard a cruise ship Unedited CRA Tags 20(10) Dear Sirs: This is in reply to your letter of May 23, 1990, concerning the deductibility of expenses relating to a convention to be held aboard a cruise ship. The Department's position as set out in paragraph 2 of Interpretation Bulletin IT-131R2 is that a convention held during an ocean cruise is considered as being held outside the territorial scope of the organization. Since subsection 20(10) of the Income Tax Act requires the convention to be held at a location that can reasonably be regarded as consistent with the territorial scope of the organization it is our view that the expenses relating to a convention that your clients propose to hold during an ocean cruise (a cruise to Alaska is considered an ocean cruise) would not be deductible by the members. ...

24 July 1990 Income Tax Severed Letter ACC9404- Deductibility of Convention Expenses 24(1) 900982 W.P. Guglich (613) 957-2102 Attention: 19(1) JUL 24 1990 Dear Sirs: This is in reply to your letter of May 23, 1990, concerning the deductibility of expenses relating to a convention to be held aboard a cruise ship. ... Since subsection 20(10) of the Income Tax Act requires the convention to be held at a location that can reasonably be regarded as consistent with the territorial scope of the organization it is our view that the expenses relating to a convention that your clients propose to hold during an ocean cruise (a cruise to Alaska is considered an ocean cruise) would not be deductible by the members. ...

2003 Ruling 2003-0032923- Article X(2)(a) US Convention & Drupa Also released under document number 2003-00329230. ... Reasons: XXXXXXXXXX is a resident of the U.S. pursuant to A.IV(1) of the Convention. ... Herein "Act" means the Income Tax Act, R.S.C. 1985 c.1 (5th Supplement), as amended to the date hereof and "Convention" means the Canada-United States Income Tax Convention (1980). ...

31 July 1990 External T.I. 9003435 F- Canada-USSR Tax Convention- Deemed USSR Residence Unedited CRA Tags 14(a), 14(1), 2(b), 2(c)   G. ... If it is determined that     19(1)     is a resident of the USSR under paragraph 1 or 2 of Article 4 of the Convention for a particular year, the provisions of Article 12 of the Convention will be available to him for the year.  On the other hand, if it is determined that     19(1)     is a resident of Canada under paragraph 2 of Article 4 of the Convention for a year, the provisions of Article 12 of the Convention will not be available to him for the year. ...

7 December 1990 Income Tax Severed Letter- Canada-Netherlands Income Tax Convention Unedited CRA Tags Canada–Netherlands Income Tax Convention, Art. 3, 4, OECD Model Double Taxation Convention of 1977 Dear Mr. ... In our view, the wording of paragraph 3 of Article 4 of the Canada- Netherlands Income Tax Convention has the same effect. ... Where agreement cannot be reached, the corporation will not be a resident of either State for most purposes of the Convention. ...

19 May 1987 Income Tax Severed Letter 5-3225- [Article XVII of the Canada-UK Tax Convention] XXXX D. ... With regard to 1985, paragraph 1 of Article XVII of the Canada-United Kingdom Tax Convention (1978) (the "Convention") as it read before its amendment on April 6, 1986 permits the United Kingdom to tax Canadian-sourced pensions received by a resident of the United Kingdom. ... As you are aware, Article XVII of the Convention was amended effective April 6, 1986. ...