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This new exemption is described in article 12(7) of the Canada‑Estonia tax convention. ... Organizations – Under Article XXI of the Canada – United States Tax Convention. ... Income Tax Act, subsection 212(4) or business profits article of a tax convention signed by Canada. ...

The relevant tax convention must then be examined to determine whether there is any tax relief provided therein, such as an exemption or a reduction in the Part XIII withholding rate. ... It is important to note that Article XII of the Canada-United States Tax Convention (1980) was amended in the Third Protocol (1995) to expand the class of royalties exempt from withholding tax at source. ... Granite Bay Timber Co., 59 DTC 1262 and Boardman v. the Queen, 85 DTC 5628. 4 Model Tax Convention on Income and on Capital, Organization for Economic Co-Operation and Development (2003) Commentary on Article 12, paragraph 11.4. 5 Ibid Date modified: 2016-02-23 ...

Income Tax Act, subsection 212(4) or business profits article of a tax convention signed by Canada Exemptions for payments made to non-resident tax-exempt persons Exemption code for payments made to non-resident tax-exempt persons Code Description References I Article XXI of the Canada − United States Tax Convention: Exemption for organizations that have received a letter of exemption under Article XXI of the Canada – United States Tax Convention. ... Organizations- Under Article XXI of the Canada- United States Tax Convention Other exemptions Exemption codes for other exemptions Code Description References Q Payments to a non-resident that carries on a business in Canada through a permanent establishment in Canada: Exemption under a tax convention between Canada and another country on dividend, interest, and royalty payments. ... T Other exempting provisions: Exemption from withholding tax as a result of other exempting provisions of a tax convention, other than those given above in codes I, and P through R. ...

When not to make your request online You cannot make your request online if: you want to adjust another type of return (such as Form GST106, Information on Claims Paid or Credited for Foreign Conventions and Tour Packages). ...

. ¶1.10 has been added to note the amendments to section 4.3 of the Income Tax Conventions Interpretations Act as it relates to the deemed residence of a trust under subsection 94(3). ¶1.11 (formerly ¶10 of IT-447) has been amended to reflect the legislative change made by S.C. 2013, c. 40 (formerly Bill C-4) that a trust must be resident in Canada in order for the attribution rule in subsection 75(2) to apply in respect of property held by the trust. ¶1.12 has been added to note that subsection 250(6.1) will deem a trust that ceases to exist at any time in a tax year, and that was resident in Canada immediately before it ceased to exist, to be resident in Canada during the remaining period in the year. ...

. ¶1.10 has been added to note the amendments to section 4.3 of the Income Tax Conventions Interpretations Act as it relates to the deemed residence of a trust under subsection 94(3). ¶1.11 (formerly ¶10 of IT-447) has been amended to reflect the legislative change made by S.C. 2013, c. 40 (formerly Bill C-4) that a trust must be resident in Canada in order for the attribution rule in subsection 75(2) to apply in respect of property held by the trust. ¶1.12 has been added to note that subsection 250(6.1) will deem a trust that ceases to exist at any time in a tax year, and that was resident in Canada immediately before it ceased to exist, to be resident in Canada during the remaining period in the year. ...