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13 December 1990 Internal T.I. 902529 F- Canada-Sweden Income Tax Convention on Taxation of Insurance Policy Unedited CRA Tags n/a 24(1) 902529   J.P. ... Furthermore, the provisions of the Canada-Sweden Income Tax Convention may be applicable to override the provisions of the Income Tax Act of Canada. ... We would caution that many of the comments in these publications are general in nature and that, when considering any particular circumstance, reference should be made to the Income Tax Act of Canada and the Canada-Sweden Income Tax Convention. ...

7 August 1990 Income Tax Severed Letter- Calculation of gains exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XIII Dear Sirs: Re: Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your letter dated May 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

10 January 1992 Roundtable, 9122140- Convention entre actionnaires Unedited CRA Tags 55(3)(a)   TABLE RONDE- CGA- 10 JANVIER 1992 Agent: P. Diguer Dossier: 7-912214 QUESTION #9 Dans une situation similaire à la question précédente, A et B ont une convention entre actionnaires dans A Ltée comportant des clauses visées par le paragraphe 251(5)b) de la loi (ex: obligation d'acheter et de vendre advenant certains événements comme le retrait des affaires) et que cette convention est reconduite pour la détention des actions de B Ltée.  ... Le Ministère est-il d'accord avec une telle conclusion si les clauses des conventions ne sont pas visées par la position contenue au IT-64R2? ...

18 April 1990 Income Tax Severed Letter ACC9185- Canada-China Income Tax Convention on Interest on Deposits Earned in Canada 19(1) Jim Wilson (613) 957-2063 HBW 4125-C2 HBW 6591-C2 April 18, 1990 Dear 19(1) Re: 24(1) Article XI of the Canada-China Income Tax Convention We are writing in regard to your letter dated January 17, 1989 (copy attached), in which you requested confirmation on the tax status of the 24(1) regarding interest earned on deposits held in Canada. Our Vancouver District Office replied to the letter on April 4, 1989 (copy attached) and acknowledged tax exemption to the 24(1) in accordance with paragraph 3, Article 11 of the Canada-China Income Tax Convention. ... Article 3 of Convention delegates the competent authority function to your Ministry of Finance ar its authorized representative. ...

Income Tax Convention, 1980] Revenue Canada Taxation Head Office Attention: XXXX T.B. ... Income Tax Convention, 1980 This is in reply to your letter of July 29 regarding the above-referenced subject. ... Income Tax Convention, 1980 (the "Convention") would apply in a situation where a Canadian resident individual elects under subsection 85(1) of the Act on the transfer of his interest in a U.S. partnership to his wholly-owned Canadian corporation. ...

Income Tax Convention and RCAs] K.B. Harding (613) 957-2129 November 10, 1987 Dear Sirs: This is in reply to your letter of September 10, 1987 concerning the application of the Canada- U.S. Income Tax Convention (Convention) to retirement compensation arrangements (RCAs) as proposed in Bill C-64. ... Paragraph 2 of Article XXI of the Convention also provides an exemption from withholding tax on interest and dividends derived by an organization which is "generally exempt from tax in a taxable year" and is "constituted and operated exclusively to administer or provide benefits under one or more funds or plans established to provide pension, retirement or other benefits". ...

Income Tax Convention- Lump Sum Withdrawal from RRSP Unedited CRA Tags n/a 19(1) File No. 5-9277   D. ... Tax Convention. It is our position that a full or partial lump sum withdrawal from a RRSP would not be considered a pension for purposes of Article XVII(1) of the Canada-U.K. Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

5 October 1989 Ruling HBW41253 F- Canada-Austria Income Tax Convention Unedited CRA Tags n/a 19(1) David R. ... Pursuant to paragraph 3 of article XXV of the Canada-Austria Income Tax Convention (1976) and in our capacity as Canadian competent authority we wish to confirm our agreement with the following interpretation of Article XIX of the said Convention. ...

Income Tax Convention- Lump Sum Withdrawal from RRSP Unedited CRA Tags n/a 19(1) File No. 5-9445   D. ... Tax Convention to lump sum withdrawals from a Registered Retirement Savings Plan (RRSP). ... Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

15 February 1990 Ruling HBW4125U31A F- Canada-US Income Tax Convention- Interest Income Exemption Unedited CRA Tags Can. ... 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. ...