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19 April 1991 External T.I. 9105075A F- Canada-France Tax Convention- France Pension Plan Unedited CRA Tags 6(1)(a)   5-910507 Dear Sirs: Re:  Our letter of April 4, 1991 Further to the above-noted letter and our telephone conversation of April 15, 1991, this is to advise that Article 29 of the Canada-France Tax Convention (1975) contains a provision which may be applicable to the situation on which you asked us to comment. ...

20 December 1994 External T.I. 9421435- ROYALTIES AND CANADA-UK INCOME TAX CONVENTION Unedited CRA Tags 212(5) Art 12(3) 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. ... Income Tax Convention; the said payments representing copyright royalties in respect of the reproduction of any literary, dramatic, musical or artistic work other than in respect of motion pictures and works on film, videotape or other means of reproduction for use in connection with television broadcasting. ...

8 December 1994 External T.I. 9414455- ARTICLE XXI, PAR.2 OF THE CANADA-U.S CONVENTION Unedited CRA Tags 212(1)(b)(iv) 212(14) 215(1) ART XXI 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. ... Income Tax Convention(1980) (the "Treaty). This is in reply to your letter dated February 28, 1994 (received by fax in our office on June 3, 1994) wherein you asked us to confirm that the interest payments made by employees resident of Canada to certain retirement plans resident in the United States would be exempt from Canadian withholding tax under Part XIII of the Income Tax Act (the "Act"), by virtue of Article XXI, paragraph 2 of the Treaty. ...

Income Tax Convention (1980) (the "U.S. Convention")? Our Comments Your letter describes factual situations involving a specific taxpayer. ... German Convention The relevant part of Article 11 of the German Convention provides: 3. ... Convention The relevant part of paragraph 3 of Article 11 of the U.S. ...

Conventions fiscales Accord entre le Canada et la République fédérale d'Allemagne En vertu de l'alinéa 3(c) de l'article 18 de cette convention, les prestations payées en vertu de la législation sur la sécurité sociale dans un État contractant (Allemagne) à un résident de l'autre État contractant (Canada) sont imposables dans cet autre État (Canada). ... La Reine, [1998] 4 CTC 2232 comme étant des paiements de sécurité sociale pour les fins du paragraphe 2 de l'article 18 de la convention fiscale intervenue entre le Canada et la Belgique. ... Il est donc pertinent de le considérer comme tel pour les fins des dispositions de la convention fiscale conclue entre la Canada et la France. ...

Principal Issues: Can an election be made under paragraph 7 of Article XVIIII of the Canada-United States Income Tax Convention (the "Convention") with respect to income of a Roth IRA otherwise taxable in the hands of a Canadian resident beneficiary? ... Leung December 11, 2002 Dear XXXXXXXXXX: Re: Taxation of Roth IRA Income and Withdrawals under Article XVIII of the Canada-United States Income Tax Convention (the "Convention") This is in reply to your letter of July 16, 2002 in which you requested our opinion as to whether paragraph 1 of Article XVIII of the Convention would apply to exempt Roth IRA withdrawals of a U.S. citizen resident in Canada (the beneficiary) from Canadian taxation and whether paragraph 7 of that Article would apply to allow the beneficiary to make an election to defer taxation in Canada with respect to capital gains realized in the plan but not distributed by the plan. The reason you have limited your enquiry regarding the application of paragraph 7 of Article XVIII of the Convention to capital gains is that you are of the understanding that interest and dividends earned by the Roth IRA are not taxable in the hands of the beneficiary pursuant to paragraph 2 of Article XXI of the Convention. ...

Reasons: Application of the Act and the Convention XXXXXXXXXX 2013-050977 S.E. ... The terms "real property" and "immovable property" are defined in section 5 of the Income Tax Conventions Interpretation Act ("ITCIA") for purposes of Canada's tax conventions, as follows: 5. Definitions — Notwithstanding the provisions of a convention or the Act giving the convention the force of law in Canada, in this section and in the convention, "immovable property" and "real property", with respect to property in Canada, are hereby declared to include (a) any right to explore for or exploit mineral deposits and sources in Canada and other natural resources in Canada, and (b) any right to an amount computed by reference to the production, including profit, from, or to the value of production from, mineral deposits and sources in Canada and other natural resources in Canada; Therefore, if Mr. ...

You have indicated that you are currently filing your tax returns in XXXXXXXXXX based on Article XXVII of the Canada XXXXXXXXXX Tax Convention (the "Tax Convention") and paragraph 2 of Article 37 of the Vienna Convention on Diplomatic Relations (the "Diplomatic Convention"); and that as long as you continue to serve as XXXXXXXXXX staff of the XXXXXXXXXX Embassy you will be a fiscal resident of XXXXXXXXXX pursuant to Article XIX of the Tax Convention. ... The FMIOA gives certain articles of the Diplomatic Convention and the Vienna Convention on Consular Relations (the "Consular Convention") the force of law in Canada. ... Residency for purposes of the Tax Convention is generally determined under Article IV of the Tax Convention. ...

deemed to be a resident of XXXXXXXXXX, or exempt from tax, under the Canada XXXXXXXXXX Tax Convention (the "Tax Convention"). ... The FMIOA gives certain articles of the Vienna Convention on Diplomatic Relations (the "Diplomatic Convention") and the Vienna Convention on Consular Relations (the "Consular Convention") the force of law in Canada. ... Residency for purposes of the Tax Convention is generally determined under Article IV of the Tax Convention. ...

The Partners are both residents of the United States for purposes of the Canada-United States Income Tax Convention (the "Convention"). ... Neither of the Partners has a permanent establishment ("PE") in Canada for purposes of the Convention. ... Issue 1: If Part XIII tax applies, is it limited to the rate set under the Convention? ...