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17 September 2007 External T.I. 2007-0250101E5- Article 12(4) of Canada/Switzerland Tax Convention Principal Issues: Whether an aircraft would be considered to be equipment for the purposes of Article 12(4) of the Canada-Switzerland Tax Convention. ... Zhang (613) 957-2104 September 17, 2007 Dear XXXXXXXXXX: Re: Article 12(4) of the Canada-Switzerland Tax Convention We are writing in response to your letter of August 16, 2007 in which you requested our comments regarding the tax treatment of payments for the use of an aircraft under the Canada-Switzerland Tax Convention (the "Treaty"). ...

ACC 8675 F- Canada-France Income Tax Convention on Pensions Unedited CRA Tags n/a   September 28, 1989 S. ... Senécal   957-2074      HBW 4125-F1 19(1) Paragraph 5 Article XXIX  Canada-France Income Tax Convention As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada.  ...

7 October 2010 External T.I. 2009-0344201E5- Canada-US Tax Convention Unedited CRA Tags Articles IV(7)(b), XXI, XXIX A Canada-US Tax Convention Principal Issues: Is a US charitable organization eligible for the exemption from Canadian withholding tax provided in Article XXI of the Convention in respect of an item of income received from a Canadian-resident ULC that is fiscally transparent under the laws of the US? ... Kauffman Attention: XXXXXXXXXX October 7, 2010 Dear Sirs: Re: Canada-United States Tax Convention This is in reply to your correspondence of September 21, 2009. ... Tax Convention (the "Treaty"). The income of the US LP is allocated to the Limited Partner and General Partner in proportion to their partnership interests. 3) US LP owns all of the issued and outstanding shares and debt of a Nova Scotia Unlimited Liability Company ("Canco"). ...

16 June 1991 External T.I. 9113055 F- Canada-Italy Income Tax Convention Unedited CRA Tags 2(1), 126(1), 126(7) non-business income tax, Treaty Italy 5-911305 Dear Sirs: Re:  Canada-Italy Income Tax Convention This is in reply to your letter of May 7, 1991 wherein you requested our views on the income tax liabilities of a Canadian resident in the following hypothetical situation as outlined in your letter. ... X is employed in Italy by an employer that does not have a permanent establishment (within the meaning of Article V of the Canada-Italy Income Tax Convention Act,1980 (the "Tax Treaty") or other fixed base in Canada. 3.      ...

Income Tax Convention Unedited CRA Tags n/a 24(1) 900875   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9246 August 30, 1990 Dear Sirs: Re:  Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your reply to your letter dated May 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

Income Tax Convention- Mine and Mill Unedited CRA Tags 7(b) 5-8648 Dear Sirs: Re: Article 13 of the Canada-United Kingdom Income Tax Convention (the "Treaty") This is in reply to your letter dated August 31, 1989 whereby you requested our opinion concerning the application of paragraph 7(b) of Article 13 of the Treaty to a mine and a mill.  ...

8 January 2004 External T.I. 2003-0049781E5- Article IV of the Canada-US Convention Unedited CRA Tags 212(2) 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. ... XXXXXXXXXX 2003-004978 January 8, 2004 Dear Sir: Re: Article IV of the Canada-United States Income Tax Convention We are writing in response to your correspondence of November 20, 2003 concerning Article IV of the Canada-United States Income Tax Convention (the "Treaty") to a U.S. trust ("UST") in the following situation: 1. ...

12 February 2010 External T.I. 2010-0355661E5- Article IV(6) of the Canada-US Tax Convention Unedited CRA Tags Canada-US Tax Convention Article IV(6); Fifth Protocol Article 27(2)(b) Principal Issues: Where a US resident corporation derives business income through a US Limited Liability Company (USLLC), which entity's taxable year is relevant when considering the coming into force provision in subparagraph 2(b) of Article 27 of the Fifth Protocol? ... Tax Convention This is in response to your email dated January 25, 2010 regarding the application of paragraph IV(6) of the Canada-United States Tax Convention ("the Treaty") in the context of the facts given below. 1. ...

Tax Convention Unedited CRA Tags Article IV(7)(b) of the Convention Principal Issues: Does Article IV(7)(b) of the Convention apply in the scenarios described below? Position: See response XXXXXXXXXX 2009-034629 Katharine Skulski March 11, 2010 Dear XXXXXXXXXX: Re: Article IV(7)(b) of the Canada-United States Tax Convention (1980) (the "Treaty") This is in response to your letter of November 2, 2009 concerning the application of Article IV(7)(b) of the Treaty in the scenarios described below: Scenario 1 USCo is a resident of the United States for the purposes of the Treaty. ...

18 January 2008 External T.I. 2005-0140291E5- Article XXI of the Canada-US Tax Convention Unedited CRA Tags Article XXI Canada US Tax Convention Principal Issues: Interest and dividend derived by certain qualifying U.S. pension funds are exempt from Canadian non-resident withholding tax pursuant to paragraph 2 of Article XXI. ... Income Tax Convention This is in reply to the letter of June 29, 2005 sent by XXXXXXXXXX in which he requested our views with respect to Article XXI(2) of the Canada-U.S. Income Tax Convention (hereinafter the "Treaty"). We apologize for the delay in responding. ...