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Principales Questions: Impacts fiscaux de la continuation de l'existence d'une société en une coopérative Position Adoptée: Aucune Raisons POUR POSITION ADOPTÉE: Les impacts fiscaux ne peuvent être déterminés sans un examen détaillé des faits, des conventions et des droits des actionnaires. ...

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. ...

Income Tax Convention (1978) does not provide any relief in this regard. ...

Income Tax Convention (1978) does not provide any relief in this regard. ...

Instead, the lending fee would either be subject to tax pursuant to subparagraph 212(1)(d)(i) of the Act for the use of property in Canada or will be considered business profits in accordance with the provisions of Article V and VII of the Canada-United States Tax Convention (1980). ...

Tax Convention 1980 to the type of transactions described above. This memo also points out that, generally, for Canadian resident shareholders who are not citizens of the U.S. there is no potential for double taxation and that there may be relief from double taxation of Canadian resident shareholders who are U.S. citizens if they apply to the U.S. tax authorities for such relief. ...

The Canada-United States Income Tax Convention (1980) does not provide for a reduction of Part XIII tax on such rental income.       ...

Income Tax Convention permits Canada to tax such royalty payments made to U.S. residents, however, the rate of withholding tax on such payments is limited to 10% of the gross amount of the royalty payments. 21(1)(b) for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch ...

Income Tax Convention (1978) (if applicable) or other rate of withholding tax normally applied on payments to non-residents.  ...

Position: 1) Yes, if any income is payable to the beneficiaries prior to the wind-up of the estate. 2) Article 21 of the Canada-Poland Tax Convention reduces the 25% rate to 15% where the income is taxable in Poland. ... Article 21 of the Canada-Poland Tax Convention reduces the 25% rate to 15% where the income from the trust or estate is taxable in Poland; otherwise the rate remains at 25%. ... Article 21 of the Canada-Poland Tax Convention reduces this rate to 15% where the income from the trust is taxable in Poland: otherwise the rate remains at 25%. ...