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Technical Interpretation - External

25 January 2012 External T.I. 2012-0434121E5 - Obligation to make remittances

Therefore, even if the provisions of the Income Tax Act and Canadian social security legislation were interpreted to apply to embassies in Canada, those embassies enjoy immunity from these statutes as a result of the State Immunity Act, the Vienna Convention on Diplomatic Relations (arts. 23 and 33) and customary international law. ...
Technical Interpretation - External

20 August 1997 External T.I. 9719875 - LRIF, RRIF

Sarazin Attention: XXXXXXXXXX August 20, 1997 Dear Sirs: Re: Withholding Tax from a LRIF This is in reply to your facsimile received on July 23, 1997, wherein you requested confirmation that a life retirement income fund ("LRIF") would be treated like a registered retirement income fund ("RRIF") for purposes of determining the withholding taxes required under the Canada-Mexico Income Tax Convention (1991). ...
Technical Interpretation - External

4 January 1999 External T.I. 9817575 - FOREIGN PENSION PLANS

Income Tax Convention (1978) does not provide any relief in this regard. ...
Technical Interpretation - External

17 February 1995 External T.I. 9416385 - CENTRE OF VITAL INTERESTS (HAA 7576-1)

Accordingly, the applicable District Taxation Office should be consulted with respect to the determination of the centre of vital interests of such a taxpayer for purposes of the Canada-Germany Income Tax Agreement (the "Convention"). ...
Technical Interpretation - External

1995 External T.I. 9422575 F - CHOIX TARDIF

Ceci pourrait être considéré être le cas si tous les documents corporatifs et les conventions de transfert indiquent clairement que l'intention des parties était d'effectuer un tel choix, et indiquent clairement les sommes convenues. ...
Technical Interpretation - External

23 October 2003 External T.I. 2003-0004415 - Arizona LLC

Income Tax Convention. Yours truly, Olli Laurikainen Section Manager for Director International and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch- 2- ...
Technical Interpretation - External

4 February 2002 External T.I. 2000-0053595 - Limited Liability Company

Income Tax Convention. These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001, issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...
Technical Interpretation - External

29 January 2002 External T.I. 2001-0067735 - Limited liability company

Income Tax Convention. These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001, issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...
Technical Interpretation - External

29 January 2002 External T.I. 2001-0083545 - Limited liability company

Income Tax Convention These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001, issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...
Technical Interpretation - External

29 January 2002 External T.I. 2001-0084805 - Limited Liability Corporation

Income Tax Convention. These comments are provided in accordance with the guidelines set out in paragraph 22 of IC 70-6R4 and are not considered binding on the CCRA. ...

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