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16 June 2010 Roundtable, 2010-0369271C6- Canada-US Tax Convention- Treatment of LLCs Unedited CRA Tags Article IV of the Canada-US Tax Convention Principal Issues: Impact of the Tax Court of Canada decision in TD Securities (USA) LLC Position: See response Reasons: See response CANADIAN PETROLEUM TAX SOCIETY 2010 ANNUAL CONFERENCE TD Securities (USA) LLC Decision On April 8, 2010, the Tax Court of Canada rendered its judgment in TD Securities (USA) LLC v. ... (endnote 1) The Court concluded that TD Securities (USA) LLC, a limited liability company ("LLC") formed under United States law, was entitled to benefits under the Canada-United States Tax Convention (1980) (the "Treaty"). ...

7 November 1987 Income Tax Severed Letter RRRR120- Information Circular 76-12R3 Footnote (6) Canada-Norway Income Tax Convention Unedited CRA Tags 212(1)(d) As discussed with you in a recent telephone conversation, we suggest that you consider amending Information Circular 76-12R3 to clarify the Department's position on the rate of withholding tax that applies to rental income from moveable property received by a resident of Norway from a resident of Canada. ...

Income Tax Convention on Pensions Unedited CRA Tags n/a 19(1) Jim Wilson   (613) 957-2063   HBW 4000-3 April 30, 1990 Dear 19(1) We are writing in regards to your letter dated April 14, 1990, concerning the tax treatment of certain pensions upon immigration to Canada. Pursuant to Article 18 of the Canada-United States Income Tax Convention, pensions (other than benefits received under U.S. social security legislation or pensions that would otherwise be exempt form U.S. tax if you remained a resident thereof) arising in the United States and paid to a resident of Canada (i.e. you would be considered a resident of Canada upon immigration) may be taxed in both countries.  ...

Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. ...

Income Tax Convention] MEMORANDUM March 10, 1983 TO Provincial and International Relations Division Mr. ... Income Tax Convention (1978) (the "Treaty") We enclose the letter dated December 20, 1982 from XXXX concerning the above-mentioned Treaty and its application to a repurchase of shares by a U.K. corporation from an individual shareholder who is resident in Canada or from a corporate shareholder which is resident in Canada and owns less than 10% of the voting power of the U.K. corporation. ...

19 December 1986 Income Tax Severed Letter 5-2426- [Canada-Switzerland Income Tax Convention] XXXX G. Thornley (613) 957-2130 December 19, 1986 Canada-Switzerland Income Tax Convention (the "Treaty") This is in reply to your letter of October 29, 986 requesting a technical interpretation of the provisions of Article XIII of the above noted treaty in a hypothetical fact situation. ...

Income Tax Convention on Pensions Jim Wilson (613) 957-2063 HBW 4000-3 April 30, 1990 Dear 19(1) We are writing in regards to your letter dated April 14, 1990, concerning the tax treatment of certain pensions upon immigration to Canada. Pursuant to Article 18 of the Canada-United States Income Tax Convention, pensions (other than benefits received under U.S. social security legislation or pensions that would otherwise be exempt form U.S. tax if you remained a resident thereof) arising in the United States and paid to a resident of Canada (i.e. you would be considered a resident of Canada upon immigration) may be taxed in both countries. ...

2002 Ruling 2001-0112133- Article XIII of Canada-XXXXXXXXXX Convention Unedited CRA Tags Art. ... Principal Issues: Whether a XXXXXXXXXX is a "property, other than rental property, in which the business of the company... is carried on" for purposes of paragraph 3 of Article XIII of the Canada-XXXXXXXXXX Income Tax Convention. ... DEFINITIONS In this letter, the following terms have the meanings specified: (a) "Act" means the Income Tax Act, R.S.C. 1985, c.1 (5th Supp.), as amended, and all references to a statute are to the Act, unless otherwise indicated; (b) "Agency" means the Canada Customs and Revenue Agency; (c) "arm's length" has the meaning assigned by Section 251; (d) "disposition" has the meaning assigned by section 248(1) of the Act; (e) "Forco1" refers to XXXXXXXXXX; (f) "Forco2" refers to XXXXXXXXXX; (g) "Forco3" refers to XXXXXXXXXX; (h) "FMV" means fair market value; (i) "Holdco" refers to XXXXXXXXXX; (j) "Forco4" refers to XXXXXXXXXX; (k) "Opco" refers to XXXXXXXXXX; (l) "Parentco" refers to XXXXXXXXXX; (m) "Subco" refers to XXXXXXXXXX; (n) "taxable Canadian corporation" has the meaning assigned by subsection 248(1) (which refers to subsection 89(1)); (o) XXXXXXXXXX; (p) "Treaty" refers to the Canada-XXXXXXXXXX Tax Convention. ...

Income Tax Convention on Pension Unedited CRA Tags n/a 19(1) 901544   G. ...

Income Tax Convention Re Withholding Tax on Pensions Unedited CRA Tags none Dear XXX We are writing in follow-up to your telephone conversation on November 23, 1990, with Mr. ...