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Tax Convention (the "Convention") and paragraph 254(a) of the Act. ... The particular provisions would be Article VIA of the Convention and paragraph 7 of the Convention Protocol. ... The old convention limited taxation of periodic pension payments, it did not limit the taxation of any other payments out of a "pension" plan nor did it expand upon the meaning of pensions to identify specific sources of the periodic payments as does the present Convention. ...

2007 Ruling 2005-0149681R3- Article XXI of Canada-US Tax Convention Unedited CRA Tags Article XXI Canada-US Tax Convention Principal Issues: Will the non-resident corporation carry on a business in Canada for the purposes of paragraph 3 of Article XXI of the Canada-US Tax Convention? ... The above rulings are based on the Act and the Tax Convention in their present form and do not take into account any proposed amendments to the Act or Tax Convention. ... OPINION The word "income" is not defined in the Tax Convention or in the Income Tax Act. ...

24 April 1990 Ruling HBW84131/4125J1 (E) F- Canada-Japan Income Tax Convention on Employment Income Unedited CRA Tags n/a 19(1) B. ... As a continuing resident of Canada, any employment income earned outside the JET Programme is subject to income tax in Canada pursuant to Article 15 of the Canada-Japan Income Tax Convention. ... Participants in the JET Programme are governed by Article 18 of the Convention and are exempt from tax in Canada based on the unique nature of the Programme.  ...

26 April 1990 Income Tax Severed Letter ACC9181- Canada-Indonesia Income Tax Convention on Interest Payments Jim Wilson 24(1) (613) 957-2063 HBW 9412-2-3 HBW 4125-I-3 April 26, 1990 Dear Sirs: We are writing in reply to your letter dated April 4, 1990 concerning tax exemption on interest payments made to the 24(1) 24(1) An agreement under paragraph 7(c) of Article XI of the Canada-Indonesia Income Tax Convention can only be finalized by an exchange of letters between the competent authorities of the two contracting states. Paragraph 1(f)(ii) of Article III of the Convention delegates the competent authority function to your Minister of Finance or his duly authorized representative. ... We suggest that you contact your Ministry of Finance and request that they initiate action to have the 24(1) recognized under Article XI of the Convention. ...

15 February 1990 Income Tax Severed Letter ACC8750- Canada-Italy Income Tax Convention- Interest Income Exemption Unedited CRA Tags Canada-Italy Income Tax Convention Article XI EACC8750 Jim Wilson (613) 957-2063 19(1) HBW 6591-I-4 HBW 4125-I-7 February 15, 1990 Dear 19(1) Re: Special Section for 24(1) We are writing in follow-up to our telephone conversation on February 13, 1990, in which you requested confirmation as to the status of the above-noted institution under Article XI of the Canada- Italy Income Tax Convention. Paragraph 3(c) of the Convention states that "notwithstanding the provisions of paragraph 2, interest arising in one of the Contracting States shall not be taxable in that State if the interest is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by any institution specified and agreed in letters exchanged between competent authorities of the Contracting State". ...

Tax Convention] Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Tax Convention (the Convention) in circumstances involving a merger of two non-resident corporations. ...

Income Tax Convention- Interest Income Exemption Unedited CRA Tags Canada–U.S. ... Pursuant to Article XI, subparagraph 3(a) of the Canada-United States Income Tax Convention, interest income arising in Canada and paid to the corporation is exempt from tax in Canada. ... In the event of a change in status of the Corporation or an amendment or repeal to Article XI of the Convention (i.e. ...

Income Tax Convention Unedited CRA Tags 126(1), Canada–U.S. Tax Convention Canada-U.S. ... XXX Article XIX of the Canada-United States Income Tax Convention (1980) is not applicable in these circumstances because the remuneration paid by Canada is not paid to a citizen of Canada. Where the remuneration is derived by a resident of Canada, Article XV of the Convention states that the employment income shall be taxable in Canada. ...

As a continuing resident of Canada, any employment income earned outside the JET Programme is subject to income tax in Canada pursuant to Article 15 of the Canada-Japan Income Tax Convention. ... Participants in the JET Programme are governed by Article 18 of the Convention and are exempt from tax in Canada based on the unique nature of the Programme. ... The initiative of and the employment by the Japanese government together with the additional responsibilities of the participants bring the participants into Article 18 of the Convention. ...

Tax Convention- Article 17 and Section 217 Election under the Income Tax Act] M.D. ... Tax Convention- Article 17 and Section 217 Election under the Income Tax Act This is in reply to your letter of January 16, 1987, in which you requested our comments on the treatment to be accorded pension income received by a U.K. resident from Canada where a section 217 election is made under the Income Tax Act (the "Act"). ... Income Tax Convention (the "Convention."), but "pensions" do not include lump sum payments out of an RRSP or pension plan. 2. ...