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Officials of the Department of Finance and the CRA will be going to Washington towards the end of the month to meet with their American counterparts on the Fifth Protocol to the Canada-United States Income Tax Convention. ...

Income Tax Convention) of the retiring allowance and to forward that amount to the Receiver General on behalf of the non-resident. ...

However, if the Taxpayer was a U.S. citizen, the foreign tax credit in respect of the U.S. tax paid on the Deemed Distribution should be computed giving consideration to subparagraph 4(a) of Article XXIV of the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital. ...

Convention with Respect to Taxes on Income and on Capital (the “Treaty”) and for Part LIX of the Regulations. ...

For more information, see the Convention between the Government of Canada and the Government of Japan. ...

Income Tax Convention (1980) which generally override the provisions of the Act. ...

However, for the purposes of Part XIII and any tax convention to which Canada is a party, an amount deemed by paragraph 260(8)(b) to be a payment of interest is deemed not to be payable on or in respect of the underlying security. ...

Currently, there is no tax convention between Canada and XXXXXXXXXX. If you require assistance in determining your mother’s residency status for 1997 and 1998, you may contact your local taxation service office. ...

Société A et Société C désirent exercer le choix prévu à l'alinéa 78(1)b) de la Loi en produisant une convention selon le formulaire prescrit, dans les délais prescrits. ...

You have also stated that, in your opinion, the definition of "dividend" in paragraph 3 of Article X of the Canada-United States Income Tax Convention (the "Treaty") "applies to treat the distribution based on the source country's tax rules" because such definition "applies the source country's tax rules in determining the character of the distribution". ...