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Income Tax Convention Unedited CRA Tags Canada/U.s. Treaty, Art. 15 Dear Sirs: Re:  Article XV(2)(b) of the Canada-United States Income Tax Convention. 1980 (the "Convention")  This is in reply to your letter dated December 6, 1990. Your proposed representation of the Department's position concerning the application of the above-noted provision of the Convention where a United States parent company ("U.S.Co. ... In our opinion, whether or not a resident of Canada is an "employer" for purposes of subparagraph 2(b) of Article XV of the Convention is essentially a question of fact.  ...

Income Tax Convention on Capital Gains Unedited CRA Tags n/a   November 20, 1989 TO  Montreal District Office FROM  Specialty Rulings   Directorate S. ... Our position is in line with the view that intent of Article XIII(9) was to effect a transition between the status of United States resident under the 1942 Convention and his status under the 1980 Convention.  ... Under the transitional provisions, in the 1980 Convention the relief therefore is the proportion of the gain from V-Day that accrued prior to December 31, 1984 (before the coming into force of the 1980 Convention).  ...

Income Tax Convention Unedited CRA Tags n/a 19(1) File No. 5-8199   R.C. ... Income Tax Convention (1980) (the "Convention") This is in reply to your letter dated July 24, 1989 regarding the above-referenced matter. ... In our opinion the word "seller" in paragraph 3(d)  of Article XI of the Convention means the original seller and would not include the assignee in either of the situations you have described.  ...

Income Tax Convention- Exemption Unedited CRA Tags n/a   February 13, 1990 To: Montreal District Office From:  Head Office Financial Industries Division Attention: Mr. ... Income Tax Convention ("Convention") Enclosed, for your information and use, are copies of our recent correspondence with 19(1) of the legal firm of 24(1) in Montreal, concerning 19(1) claim for an exemption from Canadian income tax under the Convention. ...

Income Tax Convention (the "Convention") We are writing in response to your letter of September 29, 1998 wherein you requested our views on the application Article 13 of the above-noted Convention in the circumstances described below. Background An individual (the "Taxpayer") is resident in the U.K for purposes of the Convention. ... Issues You have asked us whether any gain realized by the Taxpayer on the alienation of the shares of Canco is exempt from Canadian tax by virtue of Article 13 of the Convention. ...

Income Tax Convention Unedited CRA Tags Canada/U.S. Treaty Art. 12, 212(1)(d)(iii) Dear Sirs: Re:  Article XII of the Canada-United States Income Tax Convention. 1980 (the "Convention") This is in reply to your letter dated December 17, 1990. In our opinion, a payment arising in Canada made by a Canadian resident to a person resident in the United States (who does not have a permanent establishment in Canada) for services of an industrial, commercial or scientific character performed by the resident of the United States for the Canadian resident, which payment is dependent in whole or in part upon use, production or sales of goods or services, or profits and is a payment to which subparagraph 212(1)(d)(iii) applies, is not a "royalty" as defined in paragraph 4 of Article XII of the Convention. ...

Principal Issues: Whether individual was resident of the Dominican Republic under the Income Tax Convention. ... Our Comments We are in agreement with your conclusion that the taxpayer herein question is not a resident of the Dominican Republic under the Convention. ... Accordingly, the taxpayer is not entitled to relief from Canadian tax pursuant to the Convention. ...

Income Tax Convention- Dependent Personal Services Unedited CRA Tags n/a     EACC9681 SUBPARAGRAPH 2(a) OF ARTICLE XV OF THE CANADA-UNITED STATES INCOME TAX CONVENTION, 1980 (THE "CONVENTION")- DEPENDENT PERSONAL SERVICES Subparagraph 2(a) of Article XV of the Convention provides for an exemption on remuneration "exercised in a calender year" that does not exceed $10,000. ... REVENUE CANADA'S POSITION Subparagraph 2(a) of Article XV of the Convention exempts a resident of one Contracting State from income tax in the other Contracting State on remuneration derived in respect of an employment exercised in a calendar year in the other contracting state if such remuneration does not exceed $10,000. ...

Income Tax Convention- Retirement Compensation Arrangement Unedited CRA Tags 153(1), 212(1)(j) 19(1) File No. 5-9190   D.S. ... Convention. It is our view that the rate of tax on the amounts paid to a U.S. resident in a situation such as that described above would be 25%.  ... Convention that provides guidelines as to what constitutes a "retirement plan" for the purpose of paragraph 3 of Article XVIII thereof. ...

Income Tax Convention and Large Corporations Tax Unedited CRA Tags 181.1(3)(d), 181.4(a) 24(1) 901595   G. Arsenault   (613) 957-2126 19(1) October 24, 1990 Dear Sirs: Re:  Canada- United States Income Tax Convention, 1980 (the "Convention") and the Proposed Large Corporations Tax This is in reply to your letter dated July 13, 1990. ... Article XXIII of the Convention applies in respect of the Proposed Large Corporations Tax. 2.      ...