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Income Tax Convention This is in reply to your letter dated April 7, 1997 regarding the above-referenced matter. ... Income Tax Convention (the "Convention") provides that where under a provision of the Convention a person has been otherwise relieved from tax in a Contracting State on income that is subject to tax in the other Contracting State on a remittance basis, the relief provided under the Convention in the first-mentioned State on such income shall apply only to the amounts remitted. ... In our view, such a result is not intended by the Convention. Therefore, in the above fact pattern, it is our opinion that, as a result of the application of paragraph 2 of Article 27 of the Convention, paragraph 8 of Article 13 of the Convention would not apply to restrict Canada's right to the tax any gain on the disposition of the shares. ...

Tax Convention with respect to copyright royalties for the production and reproduction of motion pictures and other works for private home use, apply to the U.K., France and Thailand Tax Conventions. ... Tax Convention, similarly applies under the tax conventions with the United Kingdom (U.K.), France and Thailand. ... Tax Convention is similar in wording to the other tax conventions you noted, the interpretation of this paragraph is based on the technical explanation. ...

Income Tax Convention (1980) (the "Convention"). Revenue Canada has taken the position, in consultation with the Department of Finance, that tax exempt entities, including U.S. tax exempt pension trusts, are considered to be residents of the contracting state under which they are organized for purposes of Article IV of the Convention and for similar articles in other income tax conventions or agreements which Canada has in force. Accordingly, a U.S. tax exempt pension trust would therefore be entitled to all benefits under the Convention, including those contained in Articles VII, X and XIII of the Convention, notwithstanding that such entities are not "liable to tax" in the United States. The comments set out in the Technical Explanation to the Convention concerning "resident in and resident of a contracting state", in respect to Article XXI of the Convention, have been superceded by the above commments which are applicable to all of Canada's tax conventions or agreements. ...

1993 External T.I. 9315690 F- The Most-Favoured Nation Clause in Treaty with Mexico Unedited CRA Tags Treaty Mexico Article 11, Treaty Mexico Article 12 CORPORATE MANAGEMENT TAX CONFERENCEROUND TABLEJUNE 1993 Canada-Mexico Income Tax Convention (1991) Question The Protocol to the Canada-Mexico Income Tax Convention (1991) (the "Convention") provides that "In the event that pursuant to an Agreement or Convention concluded with a country that is a member of the Organization for Economic Co-operation and Development after the date of signature of this Convention, Mexico agrees to a rate of tax on interest or royalties that is lower than 15 per cent, then such lower rate (but not in any event a rate below 10 per cent) shall apply for the purpose of paragraph 2 of Article 11 with respect to interest or paragraph 2 of Article 12 with respect to royalties, as the case may be." Since the date of the signature of the Convention, Mexico has signed tax conventions or agreements ("tax treaties") with Sweden, Germany and the United States which provide for a rate of withholding tax that is lower than 15 percent in certain circumstances on interest and royalties. Does it follow that interest and royalties are now subject to a lower rate of withholding tax under the Convention? ...

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. ...

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. ...

Convention") or paragraph 5 of Article XIV of the Canada-Barbados Income Tax Convention (the "Barbados Convention"). ... Convention or paragraph 5 of Article XIV of the Barbados Convention to apply. ... Convention or Barbados Convention is relevant to determine whether Canada has the right to tax the gain. ...

Harris (613) 957-2114 July 25, 2005 Dear XXXXXXXXXX: Re: Residence Under the Canada- Switzerland Tax Convention We are writing in response to your letter of February 18, 2005 wherein you requested our comments regarding the interpretation of paragraph 5 of Article 4 of the Canada- Switzerland Tax Convention (the "Convention"). ... You have requested our opinion as to whether paragraph 5 of Article 4 of the Convention would be applicable such that the individual would not be considered a resident of Switzerland for purposes of the Convention. ... The following comments are restricted to a consideration of paragraph 5 of Article 4 of the Convention and should not be construed as signifying that the CRA has accepted that an individual who chooses to pay tax under the Swiss lump-sum basis of taxation would be considered a resident of Switzerland pursuant to paragraph 1 of Article 4 of the Convention. ...

Reasons: Wording of the Convention. XXXXXXXXXX 2003-001241 Fouad Daaboul October 1st, 2003 Dear XXXXXXXXXX: Re: The Canada-Luxembourg Tax Convention This is in reply to your letter of March 20, 2003, wherein you requested our comments on the above-mentioned subject. ... Article 28 of the Convention states in part: 3. The Convention shall not apply to holding companies within the meaning of the special Luxembourg laws (currently the Act of July 31, 1929 and the Grand Duchy Order of December 17, 1938) or any other similar law enacted in Luxembourg after the signature of the Convention, nor to companies subjected to similar fiscal laws in Luxembourg... Since the corporation is a holding company covered by the Luxembourg law of July 31, 1929, it is subject to the exception set out in paragraph 3 of article 28 of the Convention such that any other part of the Convention would generally not apply to the corporation. ...