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Periodic pension payments out of a RRIF are exempt from tax under paragraph 1 of Article XVII of the Canada-UK Convention. ... Thus, it is our view that the intention of the provisions of the UK Convention should prevail. ... 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 UK Convention specifically contemplated that payments similar to periodic pension payments would be dealt with under the term "pension". 933141 XXXXXXXXXX G. ...

Paragraph 3 of Article XXIV of the Convention reads as follows: "3. ... " Paragraph 4 Article XXIV of the Convention reads as follows: "4. ... The provision of the Convention relevant to this determination in the case of Taxpayer2 is Article XV of the Convention. ...

Cependant, aucune disposition de la Convention ne prévoit actuellement le remboursement de l’«avoir fiscal». ... La Convention modifiée n’entrera en vigueur qu’une fois ratifiée par le Président de la République française. ... A cet égard, nous vous référons au paragraphe 4 de l’article X de la Convention modifiée. ...

Furthermore, section 18 of Article V of the Convention on the Privileges and Immunities of the United Nations ("Convention") provides exemption from tax to those United Nations officials on the salaries and emoluments paid to them by the United Nations. ... The Department would recognize any tax exemptions granted to the employees and officials of the FAO pursuant to the Convention on the Privileges and Immunities of the United Nations ("Convention"). ... As pension income from the FAO is taxable under the Act, the Department must then consider the application of an income tax convention to ensure that Canada's right to tax has not been restricted or denied by the application of that particular convention. ...

Paragraph 5 of Article XXIX B of the Convention only operates where the deceased person was immediately before death a resident of the U.S. for the purposes of the Convention. In the response given below, it is assumed that in Scenario A, X was a resident of the U.S. for the purposes of the Convention immediately before death while in Scenario B, Y was not a resident of the U.S. for the purposes of the Convention immediately before death. ... Scenario B Where Y dies and is survived by X, paragraph 5 of Article XXIX B of the Convention would not apply because Y was not a resident of the U.S. for the purposes of the Convention immediately before her death. ...

Position Adoptée: Non, sauf si une convention fiscale prévoit une disposition pour alléger cet impôt. ... L'article VII de la Convention fiscale de 1980 entre le Canada et les États-Unis d'Amérique (la convention fiscale avec les États-Unis) en est un exemple. ... Article VII of the Canada-US Income Tax Convention (1980) is an example. ...

Gervais (613) 957-8953 A l'attention de XXXXXXXXXX Le 20 février 1995 Monsieur, Objet: Convention fiscale Canada-France (ci-après la «Convention») La présente est en réponse à votre lettre du 12 janvier 1995 dans laquelle vous nous demandez, en référence avec l'article XXVIII de la Convention, si la Nouvelle-Calédonie fait partie de la France. NOS COMMENTAIRES Le paragraphe 1 de l'article XXVIII de la Convention vise uniquement les départements français d'outre-mer et le territoire français de Saint-Pierre-et-Michelon. ... Par conséquent, aux fins de l'article XXVIII de la Convention, la Nouvelle-Calédonie ne fait pas partie de la France. ...

Principal Issues: Are bonds issued by the Kingdom of Morocco eligible for tax sparing under Article XXII of the Canada-Morocco Convention? ... Stalker Attention: XXXXXXXXXX January 20, 1997 Dear Sirs: Re: General Revenue Bonds Issued by the Kingdom of Morocco We are writing in response to your facsimile transmission dated September 2, 1996 in respect of the Canada-Morocco Income Tax Convention (the "Convention"). You have asked whether the tax sparing provisions in Article XXII of the Convention would apply to interest payments on bonds issued by the Kingdom of Morocco. ...

Amounts paid by a corporation resident in the United States to a corporation resident in Canada that are deemed to be dividends by and for purposes of the taxation laws of the United States may, by virtue of paragraph 3 of Article X of the Canada-United States Income Tax Convention, 1980 (the "Convention"), be deemed to be dividends for purposes of Article X of the Convention. ... Consistent with paragraph 1 of Article X and paragraph 1 of Article XI and as provided by paragraph 2 of Article XXIX of the Convention, the Convention does not affect the manner in which Canada may tax residents of Canada in respect of interest and dividends and accordingly the taxation of residents of Canada in respect of interest and dividends arising in the United States is to be in accordance with the provisions of the Income Tax Act. We cannot rule out the possibility that a taxpayer may be granted relief from taxation in a particular situation by virtue of the provisions of Article XXVI of the Convention and thus recommend that an application be made pursuant to paragraph 1 of Article XXVI of the Convention where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of the Convention. ...

The taxpayer is an individual who is a U.S. citizen and a resident of Canada for the purposes of the Canada-United States Income Tax Convention (the "Convention"). ... One of the limitations which is referred to in paragraph 3 of Article XXIX of the Convention is that the U.S. will honour its obligation under Article xxiv (Elimination of Double Taxation) of the Convention. ... The AMT which is creditable is that portion of the AMT attributable to U.S. source income resourced to Canada pursuant to the Convention. ...