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Income Tax Convention (1978) continues to apply. XXXXXXXXXX 2002-015500 T. ... Income Tax Convention (1978) (the "Tax Convention"). Our Comments Since you have asked for a simple explanation, we will limit our comments to the scenario you have provided. ... A foreign tax credit of the U.K. tax paid (i.e., the tax credit amount) would be available to a maximum of the rate specified in the Tax Convention. ...

Tax Convention (the "Convention") and paragraph 254(a) of the Act. ... The particular provisions would be Article VIA of the Convention and paragraph 7 of the Convention Protocol. ... The old convention limited taxation of periodic pension payments, it did not limit the taxation of any other payments out of a "pension" plan nor did it expand upon the meaning of pensions to identify specific sources of the periodic payments as does the present Convention. ...

Income Tax Convention (the "Convention") reduces the rate of withholding tax to 15% in the case of dividends and interest and 10% in the case of royalties. ... Dual Residency Where an individual is considered a resident of both Canada and the United States, Article IV of the Convention provides a tie-breaker rule for interpreting the Convention but does not, for Canadian tax purposes, change the fact that he continues to be a resident of Canada for Canadian taxation purposes.  ... We are enclosing a copy of the articles of the Convention referred to above and the related Technical Explanation on those articles for your convenience. ...

Income Tax Convention (the "Convention"). If such company's mind and management is in Canada, it will only be a resident of Canada for the purposes of paragraph 1 of Article IV of the Convention, paragraph 3 of Article IV of the Convention will not apply and subsection 250(5) of the Act will not apply. ...

Income Tax Convention (the "Convention"). If such company's mind and management is in Canada, it will only be a resident of Canada for the purposes of paragraph 1 of Article IV of the Convention, paragraph 3 of Article IV of the Convention will not apply and subsection 250(5) of the Act will not apply. ...

Unedited CRA Tags A.18 Canada- Netherlands Income Tax 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 CCRA. ... Pursuant to paragraph 1 of Article 18 of the Canada-Netherlands Income Tax Convention (the "Convention"), Canada retains its right to tax pension payments, and payments out of a social security system, that arise in the Netherlands and are paid on or after January 1, 1995 to a resident of Canada. Article 18 of the Convention was amended by the Protocol of March 4, 1993, to give this result. ...

As indicated to you previously by telephone, whether a resident of the United Kingdom has a permanent establishment in Canada for purposes of the Canada-United Kingdom Income Tax Convention (the "Convention") is essentially a question of fact that generally can only be determined retrospectively after all of the relevant facts have been determine and considered.  It is also essentially a question of fact as to whether an agent is an "agent of independent status" and as to whether "persons are acting in the ordinary course of their business" within the meaning of these terms as used in paragraph 5 of Article 5 of the Convention. We can, however, advise that it is our opinion that the fact that an enterprise of the United Kingdom carries on business in Canada through several agents (rather than merely one agent) of an independent status, where such persons are acting in the ordinary course of their business, does not in and of itself render paragraph 5 of Article 5 of the Convention inapplicable and does not in and of itself result in such enterprise of the United Kingdom being considered to have a permanent establishment in Canada. ...

Income Tax Convention (the "U.S. Convention"). (b)     The expression "private (home) use" is mentioned in the U.S. ... Convention.  The showing of videocassettes by airline companies, teaching establishments and military bases to their passengers, students or servicemen, respectively, cannot be said to be for "private (home) use".  ... Convention. Author:  G. MiddletonMay 1992 ...

Income Tax Convention. Principal Issues: Whether consequent to the decision of the U.K. ... Income Tax Convention is subject to the limitations imposed by subsection 126(1) of the Act. ... Double Taxation Convention of December 31, 1975 and its successor, Article 24(4)(a) of the U.K. ...

10 February 2022 External T.I. 2019-0819651E5 F- Pension from China Unedited CRA Tags Articles 18 and 20 of the Canada-China Income Tax Convention Principal Issues: Whether a pension paid to a Canadian resident individual in respect of services rendered as a public servant employee of the State of China is exempt from Canadian taxation pursuant to Article 18 of the Convention? ... Sommaire L’Article 20 de la Convention s’applique et maintient le droit du Canada à imposer la Pension puisque le bénéficiaire réside dans cet État. ... Ainsi, le paragraphe 1 de l’Article 20 de la Convention permet au Canada de conserver son droit d’imposer la Pension puisque le Contribuable y réside. ...