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Dans votre lettre, vous demandez notre opinion concernant l'application du paragraphe 3 de l'Article XIII de la Convention entre le Canada et XXXXXXXXXX (la « Convention »). ... XXXXXXXXXX (le « Vendeur ») est une société résidente XXXXXXXXXX en vertu de la Convention. 2. XXXXXXXXXX (« Canco ») est une société résidente du Canada en vertu de la Convention. 3. ...

16 June 2014 External T.I. 2014-0516451E5- Application of Canada-Israel Tax Convention CRA Tags 250(4) Treaties Article III Small Business Venture Capital Act 3(1)(a) Principal Issues: Whether a B.C. Venture Capital Corporation qualifies as a Canadian resident company for the purposes of the Canada-Israel Tax Convention Position: Yes Reasons: A B.C. ... XXXXXXXXXX 2014-051645 Sylvain Grégoire June 16, 2014 Dear XXXXXXXXXX, Re: Application of Canada-Israel Tax Convention to BC Venture Capital Corporation This is in reply to your letter dated December 19, 2013 requesting our views as to whether a B.C. ...

Income Tax Convention and sections 116 and 245 of the Income Tax Act. ... Income Tax Convention and paragraph 2 of Interpretation Bulletin IT-173R2. ... Income Tax Convention (the "Convention") and sections 116 and 245 of the Income Tax Act (the "Act") to the situation hereinafter described. ...

Neither paragraph 1 nor paragraph 2 of Article 13 of the Convention applies because Canco did not own any real property or resource property in Canada and as the income is not dealt with in the other articles of the Convention, Article 20 of the Convention applies to the gain from the disposition of such shares of Canco. ... From this perspective, section 6.3 of the ITCIA does not result in an override to any tax conventions but rather reflects the original intention of the Department of Finance when negotiating the conventions. The only reason for the phase "except where a convention expressly otherwise provides" to be in section 6.3 of the ITCIA is to clarify that section 6.3 of the ITCIA is not intended to override nor does it override the sourcing rule in the Elimination of Double Taxation Article of any convention that Canada has with the other countries (in this case, Article 21 (Elimination of Double Taxation) of the Convention or Article 22 (Source of Income) of the Australian Convention). ...

Convention Canada-Slovénie La Convention Canada-Slovénie a été signée le 15 septembre 2000 mais n'est pas encore en vigueur. La Convention Canada-Slovénie ne définit pas le terme " pension ". ... Convention Canada-Croatie La Convention Canada-Croatie a été signée le 9 décembre 1997 et est en vigueur depuis le 1er janvier 2000. ...

Income Tax Convention (1980) (the "Convention") This is in response to your memorandum of January 6, 1989 and further to our meeting of May 25, 1989. ... In addition, in the case of U.S. corporations, the claims made against the $500,000 cumulative Part XIV tax exemption referred to in Article X(6) of the Convention by the disappearing corporations would continue to affect the total claim available to the surviving corporation. ... Prescribed treaty provisions such as Article XIII(8) of the Convention clearly give the Minister the right to attach such terms and conditions. ...

Holowka 957-2126   File No. 7-3829 Subject:  Dual Residency Article IV Canada-United States Income Tax Convention (1980) (the "Convention") This is in reply to your letter of April 10, 1989 in which you asked us two questions about dual residency under the Convention. ... Article (3) of the convention of Canada not the Unites States for the proposes of the Convention because it was incorporated in Canada.  ... In our opinion paragraph 2 Article XXIX ("Article XXIX(2)") of the Convention would not affect a residency determination under the Article IV(3) of the Convention.  ...

Income Tax Convention Unedited CRA Tags 115   September 5, 1989 International Audits Division Specialty Rulings   Directorate Mr. ... Income Tax Convention (the "Convention") This is in reply to your memorandum of June 27, 1989 wherein you requested our opinion concerning the treatment of capital gains arising from the disposition of real property under Article XIII of the Convention. ... In our opinion paragraph 3 of Article XIII of the Convention was intended to tax capital gains on the disposition of shares of the capital stock of a company, the value of which is derived principally from real property as that term is defined in the Convention (i.e. including not only real property as defined in Article VI of the Convention but also shares of the capital stock of other corporations or an interest in a partnership, trust or estate which is real property as defined in subparagraph 3(b) of Article XIII of the Convention). ...

27 February 1990 Ministerial Correspondence 57484 F- Canada-Australia Income Tax Convention on Residence Unedited CRA Tags n/a 19(1) File No. 5-7484   R.C. O'Byrne   (613) 957-2126 February 27, 1990 Dear Sirs: Re:  Article 4 Canada-Australia Income Tax Convention (the "Convention") This is in reply to your letter of January 30, 1989 in which you asked whether an Australian Non-Profit Society (a "Society") would be considered a resident of Australia for purposes of the Convention.  ... Accordingly, we are of the view that Article 4(2) of the Convention would not preclude a Society from being considered resident in Australia for purposes of the Convention. ...

Our Comments Article 13 sub-paragraph 4 (a) of the Convention stipulates that the capital gain realized on the sale of the shards can be taxed in Canada, whereas by virtue of Article XVII of the Canada-Netherlands Income Tax Agreement Act, 1957, (the "Former Convention") such a gain would have been taxable only in the Netherlands.  By virtue of paragraph 3 of Article 30 of the Convention, any provisions of the Former Convention that would have afforded any greater relief from tax shall continue to have effect for any taxation year beginning before the entry into force of the Convention.  ... " The Convention entered into force on August 21, 1987, and 24(1) chose August 1, 1987 as the beginning of its fiscal period. ...