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Income Tax Convention (New)- Articles VI and XIII(9) September 4, 1985 C.G. Toussaint XXXX Dear XXXX This is in reply to your letter dated August 15, 1985, following our reply to your letters dated May 9 and August 8, 1985, concerning the application of Article XIII(9) of the Canada-United States Income Tax Convention (1980) (Convention) to resource properties. ... It is therefore our view that resource properties would not qualify for the benefits under Article XIII(9) of the Convention since they are not "capital assets" for the purposes of the Convention. ...

Reasons: Paragraph 1 to 3 of Article 6 of the Canada-United Kingdom Income Tax Convention would apply. ... Leung November 24, 2003 Dear XXXXXXXXXX: Re: The Canada-United Kingdom Income Tax Convention (the "Convention") We are writing in reply to your letter of July 3, 2003 in which you requested our view whether your interpretation of the provisions of the Convention is correct with respect to the facts of the following situation. ... Paragraphs 1 to 3 of Article 6 of the Convention read as follows: "1. ...

The Pakistani withholding tax is a tax covered by the Convention between Canada and the Islamic Republic of Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income ("Convention") in accordance with its Article II. ... Question You ask whether Article XXII of the Convention entitles Canco to claim a foreign tax credit for the amount of taxes withheld by Pakistanco. ... In this respect, the application of Articles VII and XII of the Convention to the given hypothetical situation has to be considered. ...

Cette convention a été incorporée à leur jugement de divorce du XXXXXXXXXX. ... Le XXXXXXXXXX, Monsieur et Madame ont signé une convention modificatrice des mesures accessoires. ... Par cette convention modificatrice, les parties conviennent de modifier la pension alimentaire. ...

Kuss Attention: XXXXXXXXXX March 10, 1995 Dear Sirs: Re: Article 21 of the Canada-Australia Income Tax Convention We are writing in reply to your letter dated March 7, 1995 requesting a technical interpretation regarding the application of Article 21 of the Canada-Australia Income Tax Convention (the "Convention") to the following hypothetical situation. Background A corporation which is resident in Australia under the Convention realizes a gain on the disposition of shares of a corporation resident in Canada. ... Absent any relief under the Convention the sale is taxable under the Act. ...

Tax Convention Principal Issues: Whether the Canada-US Tax Convention (“Convention”) provides relief from double taxation in circumstances where a Canadian resident is the sole member of a disregarded U.S. ... Since the SMLLC is not liable for U.S. income tax, the SMLLC is not a resident of the U.S. for purposes of applying the Canada-US Tax Convention (the “Convention”). ... As such, it is the CRA’s view that in the circumstances described there is no taxation not in accordance with the provisions of the Convention as contemplated by Article XXVI(1) of the Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII, XXII, Canada–U.K. Income Tax Convention Art. ... 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. ...

Income Tax Convention ("the Convention")? 2. Will a division of the U.S. federal government, or of a state or local government of the U.S., which is constituted and operated exclusively to administer or provide benefits under one or more funds or plans established to provide pension, retirement or other employee benefits, be eligible for the exemption from withholding tax on dividends and interest received from Canadian sources under paragraph 2 of Article 70(1) of the Convention? Discussion- Issue 1 Interpretation of the Convention Paragraph 1 of Article IV of the Convention defines a resident of a Contracting State to be "a person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature... ... Should you be unable, based upon interpreting the Convention itself, to determine that the U.S. federal, state and local governments are residents of the U.S. for purposes of the Convention, we respectfully request that consideration be given to granting such status as a response to the above-mentioned position of the U.S. government. ...

Position:- Any RRSP or RRIF payment that is a periodic pension payment (PPP) as defined under section 5 of the Income Tax Conventions Interpretation Act (ITCIA) is a pension for the purposes of Article XI of the Canada-Ireland Income Tax Agreement (the "Convention") and is exempt from tax.- Any RRSP or RRIF payment that is not a PPP as defined in section 5 of the ITCIA (e.g. a lump-sum RRSP or RRIF payment) is not a pension for the purposes Article XI of the Convention; such a lump-sum RRSP or RRIF payment is subject to tax at the rate of 15% under Article VI of the Convention which deals with other income. ... “Periodic pension payment” is defined in section 5 of the Income Tax Conventions Interpretation Act (“ITCIA”) and paragraphs (b) and (c) of the definition deal with payments under an RRSP and RRIF, respectively. ... If an RRSP or RRIF payment (e.g. a lump-sum payment) is not a “periodic pension payment” as defined under section 5 of the ITCIA, such a payment would not be a pension for the purposes of Article XI of the Convention and, accordingly, such a payment would be subject to Canadian non-resident withholding tax at the rate of 15% pursuant to Article VI of the Convention which deals with other income amounts. ...

Position:- Any RRSP or RRIF payment that is a periodic pension payment (PPP) as defined under section 5 of the Income Tax Conventions Interpretation Act (ITCIA) is a pension for the purposes of Article XI of the Canada-Ireland Income Tax Agreement (the "Convention") and is exempt from tax.- Any RRSP or RRIF payment that is not a PPP as defined in section 5 of the ITCIA (e.g. a lump-sum RRSP or RRIF payment) is not a pension for the purposes Article XI of the Convention; such a lump-sum RRSP or RRIF payment is subject to tax at the rate of 15% under Article VI of the Convention which deals with other income. ... “Periodic pension payment” is defined in section 5 of the Income Tax Conventions Interpretation Act (“ITCIA”) and paragraphs (b) and (c) of the definition deal with payments under an RRSP and RRIF, respectively. ... If an RRSP or RRIF payment (e.g. a lump-sum payment) is not a “periodic pension payment” as defined under section 5 of the ITCIA, such a payment would not be a pension for the purposes of Article XI of the Convention and, accordingly, such a payment would be subject to Canadian non-resident withholding tax at the rate of 15% pursuant to Article VI of the Convention which deals with other income amounts. ...