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29 April 2004 External T.I. 2003-0025221E5- Trusts under the Canada-US Convention Principal Issues: The application of the Canada-US convention to grantor trusts. ... The term "trust" is not defined in the Convention. Article 3 of the Income Tax Conventions Interpretation Act states: 3. ... X as a US resident for the purposes of the Convention may claim the benefits of both Articles X and XIII of the Convention. ...

17 November 2014 External T.I. 2014-0555061E5- Canada-Japan Income Tax Convention, Article 13 CRA Tags 115 248(1) "taxable Canadian property" Income Tax Convention Interpretation Act 6.3 Treaties XIII(4) Principal Issues: Meaning of expression "arising in the other Contracting State" Position: Gains from the disposition of TCP arise in Canada Reasons: See below XXXXXXXXXX Julia Belova 2014-055506 November 17, 2014 Re: Article 13 of the Canada-Japan Income Tax Convention We are writing in response to your email dated October 1, 2014 in which you enquired about the meaning of the expression "arising in the other Contracting State" in the context of paragraph 4 of Article 13 of the Canada-Japan Income Tax Convention (the "Treaty") (footnote 1). ... Pursuant to paragraph 6.3 of the Income Tax Convention Interpretation Act (Canada) (the "ITCIA"), except where a convention expressly otherwise provides, a gain from the disposition of TCP is deemed to arise in Canada. ... Yours truly, Olli Laurikainen, CPA, CA Section Manager For Division Director International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 "Convention Between The Government of Canada and The Government of Japan For The Avoidance of Double Taxation and The Prevention of Fiscal Evasion With Respect to Taxes on Income", signed on May 7, 1986, as amended by Second Protocol signed on February 19, 1999. 2 Income Tax Act (Canada), R.S.C. 1985, c.1 (5th Supp.), as amended to the date of this letter. ...

Reasons: Based on our interpretation of the Canada-Brazil Income Tax Convention and consistent with our positions in previous technical interpretations. ... OUR COMMENTS In our view, subparagraph V(2)(g) of the Convention is likely based on Article 5 of the 1963 OECD Model. ... Since the OECD Model and Commentaries, the Convention, the Income Tax Convention Interpretation Act and the Act do not define the expression "assembly project", it follows that the ordinary and common meaning of the words should prevail. ...