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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- 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.      ...

27 June 1996 External T.I. 9605225- ARTICLE XII US CONVENTION- PAYMENTS FOR USE OF DATABASE Unedited CRA Tags ART XII Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Convention- Are payments for the use of a database for the use of information concerning commercial experience? ... Convention (the ("Convention") We are writing in response to your letter dated February 1, 1996 in respect of payments made for access to a U.S. database, which followed up on our letter to you of January 22, 1996. ...

Income Tax Convention Unedited CRA Tags n/a 24(1) 902530   G. Arsenal   (613) 957-2126 19(1) November 2, 1990 Dear Sirs: Re:  Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter dated September 14, 1990 thereby you asked the following questions concerning paragraph 3 of Article 5 of the Convention: 1.      ... Paragraph 3 of Article 5 of the Convention must be interpreted by giving meaning to the words used therein. ... In our opinion, the phrase "shall not be deemed to include" in the introduction of paragraph 3 of Article 5 of the Convention is synonymous with "shall be deemed not to include". ...

Income Tax Convention Unedited CRA Tags n/a   November 2, 1989 International Audits Division Specialty Rulings S.K. ... Income Tax Convention (1980) (the "new treaty") Canada-U.S. Income Tax Convention (1942) (the "old treaty") This is in response to your memorandum of June 9, 1989. ...

23 July 1991 External T.I. 911405 F- Canada-Barbados Income Tax Convention Unedited CRA Tags 126, Treaty Barbados Article XXV Re: Canada-Barbados Income Tax Convention This is in reply to your letter dated May 21, 1991 regarding the foreign tax credit provisions of the Canada-Barbados Income Tax Convention (the "Convention").  ... It applies to give a Barbados source, for purposes of the Convention and of section 126 of the Act, to income of a Canadian resident that is taxed in Barbados in accordance with the Convention.  ... This is the lowest withholding rate of any tax convention that Barbados has concluded.  ...

CONVENTION DEEMED DIVIDEND RULE Unedited CRA Tags article 27(4) U.K. Convention Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Position: Article 27(4) of the Convention does not apply to the interest. ... Our Comments Paragraph 4 of Article 27 of the Convention while worded very broadly was in our view intended to deal only with the ACT credit referred to in paragraphs 3(b) and (c) of Article 10 of the Convention and to permit Canada to treat such tax credit as a dividend. ...

To the best of our knowledge, there was no intention in amending the ITCIA to treat periodic pension payments as annuities so that the annuity provision of an income tax convention would apply rather than the pension provision, especially where a convention such as the US Convention specifically contemplated that payments from a RRIF would be dealt with under the term "pension". ... The definition of "periodic pension payment" is found in section 5 of the Income Tax Conventions Interpretation Act (the "ITCIA"). ... Paragraph 2(a) of Article XVIII of the Canada-U.S. (1980) Income Tax Convention (the "U.S. ...

You asked us about the use of Form T2200, where school teachers were required to attend a convention in another locality and pay the related expenses. Your concern is whether the school teachers can claim the travel expenses (meals, accommodation, and transportation) they paid to attend the convention. ... These comments are consistent with paragraph 7 of Interpretation Bulletin IT-131R2 "Convention expenses" (copy enclosed), which indicates that employees are not entitled to claim convention expenses. ...