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Income Tax Convention (1980) (Convention) to provide guidelines as to what would constitute a "retirement plan" for purposes of paragraph 3 of Article XVIII of the Convention. ... Income Tax Convention (Convention). We are of the view that the term "periodic pension payment" in the Convention means a series of payments made for the purpose of providing the recipient with retirement income throughout his life or a greater part of his life. ... Tax Convention was added to clarify this matter for purposes of that Article. ...

X is a resident of Canada for purposes of the Income Tax Act (the "Act") and for purposes of the Convention. ... Provided that Airco is a resident of Cyprus for purposes of the Convention, remuneration of Mr. ... If Airco is entitled to any special tax benefit under such laws, it would not be a resident of Cyprus for purposes of the Convention and paragraph 3 of Article 15 of the Convention would not apply in respect of Mr. ...

17 July 1985 Income Tax Severed Letter July 17, 1985 Attention XXXX Dear Sirs: This is in reply to your letter dated May 9, 1985, concerning the meaning of the word "gain" as used in Article XIII of the new Canada-United States Income Tax Convention (1980) (Convention). ... Since the term "income" is not defined in the Convention, it takes on the meaning which it has under domestic law. ... When interpreting a passage of a Convention which is not clear, the Income Tax Convention Interpretations Act permits the interpreters to review the background papers and the intention of the negotiators when drafting the Convention. ...

17 July 1985 Income Tax Severed Letter July 17, 1985 Attention XXXX Dear Sirs: This is in reply to your letter dated May 9, 1985, concerning the meaning of the word "gain" as used in Article XIII of the new Canada-United States Income Tax Convention (1980) (Convention). ... Since the term "income" is not defined in the Convention, it takes on the meaning which it has under domestic law. ... When interpreting a passage of a Convention which is not clear, the Income Tax Convention Interpretations Act permits the interpreters to review the background papers and the intention of the negotiators when drafting the Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. X, XI, XII 922332 24(1) K. ... Income Tax Convention (the "Convention") This is in reply to your letter of July 28, 1992 wherein you requested our opinion concerning Article XXII of the Convention in respect to the following hypothetical situation. ... Interest paid by a U.S. resident, for the purposes of the Convention, will be deemed to arise in the United States pursuant to paragraph 6 of Article XI of the Convention. ...

The entry into force of the proposed Convention between Canada and the United States can only take place when all issues covered by the Convention have been finalized. ... On June 14, 1983, the two countries signed a Protocol to amend the earlier Convention. ... It should be noted that the current Canada-United States Income Tax Convention remains in effect until it has been superceded by the proposed Convention. ...

It is our view that it is arguable that the term "income" used in Article 21 of the Canada-Australia Income Tax Convention (1980) does not include capital gains since the Convention mentions gains specifically where it is intended that these be included. ... In addition, there arises no inconsistency between the provisions of the Income Tax Act and the Convention which would cause the Convention to prevail pursuant to subsection 6(2) of the Canada-Australia Income Tax Convention Act, 1980, so as to limit Canada's right to tax the capital gains in question. ... In summary, we are of the view that under the Convention with Australia, Canada has not given up its right to tax capital gains. ...

X peut être déclaré et imposé qu'en Suisse aux termes des articles XV et XVII de la Convention. ... X, en vertu des articles XV et XVII de la Convention, les revenus de ce dernier ont été correctement déclarés en Suisse. ... L'assujettissement des revenus est fondé initialement sur la législation fiscale des pays signataires, mais il peut être réduit en fonction des dispositions de la convention fiscale entre des pays signataires, les conventions fiscales ayant préséance sur la législation fiscale domestique. ...

Principal Issues: General questions on application of Singapore tax convention. ... Does the Convention apply to personal income tax? 2. Does the Convention apply such that once you pay Singapore income tax you are "waived from paying" Canadian income tax? ... Question 1 The Convention applies to all types of income tax imposed by Canada and Singapore. ...

Income Tax Convention (the "Convention") This is in reply to your letter of November 13, 1992. ... The partners are all residents of the United States for the purposes of the Convention. ... The Convention will not affect Canada's right to tax under that provision. ...