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Tax Convention, it is not entitled to the benefits under that Convention that require the person to be a resident of a contracting state. ... Tax conventions usually provide time limits for the taxpayer to present a case to the competent authority of taxation not in accordance with the convention. ... Tax Convention (1980) (the Convention) 64. The Convention contains certain specific provisions to relieve double taxation, as described below. ...

What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ... When was the Convention established? Q3. Why was the Convention updated in 2010? ... When will the updated Convention come into force? Q1. What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ...

What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ... When was the Convention established? Q3. Why was the Convention updated in 2010? ... When will the updated Convention come into force? Q1. What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ...

Article XXIX A Article XXIX A of the Convention CRA Canada Revenue Agency Competent Authority The Minister of National Revenue or the Minister's authorized representative the Convention The Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital Signed on September 26, 1980, as amended. ... United States of America Part I- Purpose and Scope of Article XXIX A of the Convention 3. Persons that are resident of the U.S. under Article IV of the Convention are entitled to the benefits of the Convention only if they satisfy the requirements set out in Article XXIX A. ...

Article XXIX A Article XXIX A of the Convention CRA Canada Revenue Agency Competent Authority The Minister of National Revenue or the Minister's authorized representative the Convention The Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital Signed on September 26, 1980, as amended. ... United States of America Part I- Purpose and Scope of Article XXIX A of the Convention 3. Persons that are resident of the U.S. under Article IV of the Convention are entitled to the benefits of the Convention only if they satisfy the requirements set out in Article XXIX A. ...

Canada’s tax conventions contain an article which is similar to Article 9 of the OECD Model Convention, which addresses transfer pricing adjustments. ... Specific issues under the Canada–United States Tax Convention (1980) (the Convention) Notification pursuant to Article IX (Related Persons) and Article XXVI (MAP) 79. ... The Convention (Canada-United States tax convention) does not have time limits for Articles XXVI and IX, but unlike all of Canada’s other treaties, the Convention does have a notification provision for both Articles XXVI and IX. 80. ...

Foreign Convention and Tour Incentive Program Notice to reader The information on this page replaces the information in Guide RC4160, Rebate for Tour Packages, Foreign Conventions, and Non-Resident Exhibitor Purchases, which has been eliminated. ... See, GST/HST rebate for tour packages You: are a sponsor of a foreign convention held in Canada, and paid GST/HST on a convention facility and/or related convention supplies OR are an organizer of a foreign convention held in Canada who is not registered for the GST/HST, and paid GST/HST on a convention facility and/or related convention supplies OR are a non-resident exhibitor of foreign or domestic conventions who is not registered for the GST/HST, and paid GST/HST on exhibition space and related convention supplies You may be eligible for a rebate under the FCTIP. ... What to do if you choose to credit or pay the GST/HST rebate under FCTIP to your clients If you are registered for the GST/HST, you can choose to credit or pay the rebate amount payable under the FCTIP if: you supply eligible tour packages to: non-resident tour operators non-resident individuals, businesses, or organizations (other than a tour operator) you are an organizer of a foreign convention and you supply convention facilities and/or related convention supplies to the sponsor of the convention you are an operator of a convention facility who is not an organizer of the foreign convention and you supply convention facilities and related convention supplies to one of the following: a sponsor of a foreign convention an organizer of foreign convention that is not registered for the GST/HST you are not an organizer of the foreign convention and you supply short-term accommodation or camping accommodation to one of the following: a sponsor of a foreign convention an organizer of a foreign convention that is not registered for the GST/HST Canadian suppliers cannot pay or credit the GST/HST and/or the QST to non-resident exhibitors. ...

The "Mutual Agreement Procedure" article in conventions Canada has entered into entitles a Canadian taxpayer to request competent authority assistance when the action of either government results or will result in double taxation or taxation not in accordance with the convention. ... Although in most cases the competent authorities reach agreement and relieve double taxation or taxation not in accordance with the convention, there is no appeal procedure under the conventions when agreement cannot be reached. ... Income Tax Convention (1980) 20. Generally, this convention applies to taxpayers' taxation years which start on or after January 1, 1985. 21. ...

For rebates paid or credited to a sponsor or non-registered organizer of a foreign convention, you should obtain documentation to confirm that the event was a foreign convention. ... If it is later proved that the event is not a foreign convention, we will pay back the rebate amount that the eligible supplier paid or credited for the convention facility and/or related convention supplies. ... Example – How to report on your GST/HST return an amount that you paid or credited as a rebate payable to the sponsor of a foreign convention Example – How to report an amount paid or credited on account of a rebate payable to the sponsor of a foreign convention on your GST/HST return You are the organizer of a foreign convention held in Ontario and you are a GST/HST registrant. ...

A tax convention is often referred to as a tax treaty, and the terms ‘tax convention’ and ‘tax treaty’ can be used interchangeably. ... Tax conventions ¶ 10. Negotiating new tax conventions between Canada and other countries and renegotiating existing conventions is an ongoing process. ... Some tax conventions contain an overriding provision that limits the reduction or elimination of tax provided for elsewhere in the convention. ...