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Archived CRA website
ARCHIVED - T4016 Exempt U.S. Organizations - Under Article XXI of the Canada - United States Tax Convention
Organizations- Under Article XXI of the Canada- United States Tax Convention We have archived this page and will not be updating it. ...
GST/HST Interpretation
19 September 2007 GST/HST Interpretation 97506 - Foreign Convention and Tour Incentive Program
19 September 2007 GST/HST Interpretation 97506- Foreign Convention and Tour Incentive Program Unedited CRA Tags ETA 163(3) tour package; ETA 252.1 Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... We understand that after reviewing GST/HST Notice No. 221, Questions and Answers on the Cancellation of the Visitor Rebate Program and the Implementation of the New Foreign Convention and Tour Incentive Program (the Notice), you would like clarification on when itemization on an invoice is acceptable for a tour to be considered sold for an all-inclusive price and to qualify as an eligible tour package. ... Interpretation Given For the purposes of the GST/HST rebate for tour packages under the FCTIP, an eligible tour package must: • include either short-term and/or camping accommodation in Canada and at least one service, • be sold for an all-inclusive price, and • not include a convention facility or related convention supplies. ...
Old website (cra-arc.gc.ca)
Exempt U.S. Organizations - Under Article XXI of the Canada - United States Tax Convention
In order for an IRA plan to qualify for purposes of a Letter of Exemption, the custodian/trust/individual must provide the CRA with the following information: The name of the beneficial owners of the IRAs The Tax Identification Number of the beneficial owners The addresses of the beneficial owners A notarized affidavit as to the country of residence of the holder of the IRAs and either a hard copy of the IRAs approved adoption agreement of an Individual Retirement Plan/Trust Agreement a hard copy of the custodian’s Individual Retirement Plan/Trust Agreement, and a hard copy of the fully completed IRS Form 5305 or 5305A (Name and Address) (Officer’s Name) International and Ottawa Tax Services Office Telephone: 1-855-284-5946 (Canada & USA) or: (613) 940-8499 Fax: (613) 941-6905 Attention: (Client’s Name) Date Dear Madam/Sir: Re: We are writing in response to your letter of (date), concerning application for exemption under Article XXI, Paragraph 1 of the Canada-United States Income Tax Convention (1980) (the Convention). We have reviewed your application and based on the information provided we are of the view that xxxxxxxxx as presently constituted, qualifies under Article XXI(1), of the Convention, for exemption from Canadian withholding tax on(type(s) of income) income received from Canadian sources. ... Pursuant to paragraph 4 of Article XXI of the Convention, this exemption does not apply to income earned in Canada by the organization from carrying on a trade or business, or to income from a “related person” other than a person referred to in paragraphs 1 or 2 of Article XXI of the Convention. ...
Current CRA website
Exempt U.S. Organizations - Under Article XXI of the Canada - United States Tax Convention
In order for an IRA plan to qualify for purposes of a Letter of Exemption, the custodian/trust/individual must provide the CRA with the following information: The name of the beneficial owners of the IRAs The Tax Identification Number of the beneficial owners The addresses of the beneficial owners A notarized affidavit as to the country of residence of the holder of the IRAs and either a hard copy of the IRAs approved adoption agreement of an Individual Retirement Plan/Trust Agreement a hard copy of the custodian’s Individual Retirement Plan/Trust Agreement, and a hard copy of the fully completed IRS Form 5305 or 5305A Paragraph 1 Letter (Name and Address) (Officer’s Name) Sudbury Tax Centre Telephone: 1-855-284-5946 (Canada & USA) or: (613) 940-8499 Fax: 1-855-215-6932 (Canada & USA) or: (705) 671-0342 Attention: (Client’s Name) Date Dear Madam/Sir: Re: We are writing in response to your letter of (date), concerning application for exemption under Article XXI, Paragraph 1 of the Canada-United States Income Tax Convention (1980) (the Convention). We have reviewed your application and based on the information provided we are of the view that xxxxxxxxx as presently constituted, qualifies under Article XXI(1), of the Convention, for exemption from Canadian withholding tax on(type(s) of income) income received from Canadian sources. ... Pursuant to paragraph 4 of Article XXI of the Convention, this exemption does not apply to income earned in Canada by the organization from carrying on a trade or business, or to income from a “related person” other than a person referred to in paragraphs 1 or 2 of Article XXI of the Convention. ...
Current CRA website
Exempt U.S. Organizations - Under Article XXI of the Canada - United States Tax Convention
Organizations- Under Article XXI of the Canada- United States Tax Convention From: Canada Revenue Agency Revised March 31, 2024 T4016(E) Rev.24 Clients who want a Letter of Exemption should write to the Sudbury Tax Center at the following address: Non-Resident Withholding Section Canada Revenue Agency Article XXI Post Office Box 20000, Station A Sudbury ON P3A 5C1 For more information about Letters of Exemption call us at 1-855-284-5946 (Canada and the United States), or 613-940-8499 (Outside Canada and the United States), or by fax us at 1-866-765-8460 (Canada and the United States) or 1-705-677-7712 (Outside Canada and the United States). ... Income Tax Convention with effect to March 31, 2022. Letter of Exemption Requirements: Paragraph 1 Under Paragraph 1 of Article XXI, we require the following information prior to issuing a Letter of Exemption: Articles of incorporation (to verify the purpose of the organization, the trustee information, dissolution clause, and the not-for-profit clause) A letter of favorable determination within 10 years of being issued from the Internal Revenue Service (IRS) stating that the organization is tax exempt under 501(c)(3) of the Internal Revenue Code or Form 6166 stating that the organization is recognized as a tax exempt organization per 501(c)(3) and resident in the United States Information concerning the types of income received from sources within Canada, and Address of organization Paragraph 2 Under Paragraph 2 of Article XXI, we require the following information prior to issuing a Letter of Exemption: A letter from the IRS stating that the plan is tax exempt pursuant to the Internal Revenue Code Plan documents are required to verify the: non-diversion of funds dissolution clause trustee information effective date of the trust, trustee signature, and name and address of the plan Individual Retirement Accounts (IRAs) are also exempt under Paragraph 2 of Article XXI. ... New York New York 10004-1936 09-21-2025 174330 The Nebraska Medical Center New York New York 10004 09-25-2026 175796 The New Balance Foundation Boston Massachusetts 2110 06-15-2026 175008 The North American Mission Board of the Southern Baptist Convention Inc New York New York 10004 07-12-2025 161455 The Norton Simon Foundation Bournemouth, Dorset BH7 7DA 09-26-2025 167189 The Oregon Community Foundation Towlerton, Ballysimon, Limerick V94 X2N9 null 06-23-2027 175910 The Overbrook Foundation New York New York 10004 03-12-2027 175874 The Paestum Foundation Inc New York New York 10004-1936 11-15-2026 176072 The Paul G. ...
GST/HST Interpretation
31 July 2001 GST/HST Interpretation 36822 - Organizer/Sponsor of a Convention
The application is in respect of a convention XXXXX (the convention) that was held by XXXXX in XXXXX in collaboration with the XXXXX[.] ... XXXXX has indicated that it fully financed the convention and delegated to XXXXX the task of on-site organization of the convention. Both XXXXX have indicated that XXXXX assumed responsibility for all costs related to the convention and that XXXXX acted as an intermediary of XXXXX in organizing the convention and incurring those costs. ...
GST/HST Interpretation
7 February 1995 GST/HST Interpretation 11820-1 - Related Convention Supplies
I would hasten to add that the definition of convention must be considered in its entirety to determine whether a "meeting" qualifies as a convention. ... The award ceremony must still meet the criteria and the purpose test identified in the definition of convention, to qualify as a convention. On the issue of expenses and eligibility for rebate, a sponsor of a "foreign convention" is eligible to claim the GST paid on all expenses related to the convention except those delineated in the paragraphs (a) through (d) of the definition of "related convention supplies". ...
GST/HST Interpretation
13 February 2009 GST/HST Interpretation 110305 - Foreign Convention
Therefore, the Annual Congress is a convention as defined in subsection 123(1). Definition of "sponsor" The term "sponsor", in respect of a convention, is defined in subsection 123(1), to mean the person who convenes the convention and supplies admissions to it. ... Admissions to foreign conventions Section 189.2 states, in part, that where a sponsor of a foreign convention makes a supply of an admission to the convention, the supply shall be deemed to have been made otherwise than in the course of a commercial activity of the sponsor. ...
GST/HST Interpretation
18 June 1997 GST/HST Interpretation HQR0000527[1] - Tax Status of the Supply of Admissions to a Convention
The XXXXX holds a convention on an annual basis, hosted by a club in either XXXXX or the XXXXX When the convention is held in Canada, the majority of the delegates are resident in Canada. ... When no reply was received, XXXXX contacted the Tax Services Office (TSO) and requested a ruling in regard to the convention. ... XXXXX is now requesting the GST status of the XXXXX with respect to the 19 xx convention and to future conventions, held in Canada. ...
GST/HST Interpretation
18 June 1997 GST/HST Interpretation HQR0000527[2] - Application of the GST to Supplies of Admissions to Annual Conventions
When the convention is held in Canada, the majority of the delegates are resident in Canada. • The District was of the opinion that the club should be registered for the GST because it was making taxable supplies of admissions to the convention in excess of $30,000. ... XXXXX is now requesting the GST status of the District with respect to the XXXXX convention and to future conventions, held in Canada. ... The amount collected by the District for the convention, as or on account of tax under Division II, is required to be remitted pursuant to subsection 222(1) of the Act. ...