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In the circumstances where the recipient is a non-resident residing in a country with which Canada has an income tax convention, competent authority assistance may be requested to negotiate offsetting or corresponding adjustments in order to relieve the double taxation. ...

XXXXXXXXXX 2011-042722 Philip Thompson (613) 957-2113 July 25, 2012 Dear XXXXXXXXXX: Re: Civil Penalties and Article XXVI-A We are writing in response to your letter of November 7, 2011, in which you asked for our comments in respect of the application of Article XXVI-A of the Canada-United States Tax Convention (1980) (“Treaty”). ...

The CRA stated that the impetus for the change in administrative policy is its position that the US estate tax problems applicable to Canadian residents who held US personal use real property were generally resolved by the amendments to the Canada-United States Income Tax Convention. ...

Subsection 212(2) of the Act provides for a Part XIII tax of 25% on such a deemed dividend subject to any relief under the Canada-Korea Income Tax Convention. ...

Although LEEs are subject to Canadian taxes on employment income received from a Canadian Consulate, LEEs are exempt from federal tax in the US by virtue of Article XIX of the Convention. ...

Tax Convention that apply to exempt a receipt of WHCA annuities by Canadian residents from taxation by Canada. ...

The Canada-South Africa Income Tax Convention does not prevent Canada from taxing pension benefits received by a resident of Canada. ...

Income Tax Convention (1978), a pension payment, which includes a payment out of a superannuation or pension plan according to Article XVII(3), arising in the U.K. and paid to a Canadian resident is taxable in Canada pursuant to Article XVII(1)), b) the benefit is not part of a series of periodic payments, c) the benefit is attributable to services rendered by the recipient or his spouse in a period throughout which such person was not resident in Canada, and d) the amount is designated by the taxpayer in the taxpayer’s return of income under Part I of the Act for the year. ...

In our view, these words clearly include a dividend in kind, as described above, and accordingly, such dividend would be subject to Part XIII tax at a rate of 25%, subject to any rate reduction afforded by the provisions of an applicable income tax convention. ...

Income Tax Convention. The foregoing comments represent our general views with respect to the subject matter of your letter. ...