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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. ...

En outre, pour déterminer les conséquences fiscales découlant d’un régime, on doit vérifier si la définition donnée au paragraphe 248(1) des termes “entente d’échelonnement de traitement”, “convention de retraite”, “régime de prestations aux employés”, ou “fiducie d’employée” s’applique au régime. ...

(This employment income is neither reduced nor exempt from tax in Canada by virtue of an income tax convention between Canada and the employee’s home country and the employee has no other income from a Canadian source.) ...

Seidel Attention: XXXXXXXXXX July 27, 1994 Dear Sirs: This is in reply to your letter dated April 7, 1994 requesting our views with respect to the meaning of "permanent establishment" in Article V of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

If you are aware of an industry convention of valuing certain investments on a straight-line basis (which has been accepted by the Department) and you believe the strip coupon's resemblance to such investments supports a valuation on the same basis, you may wish to mention this to the Valuations Section identified above. ...

" The Income Tax Conventions Interpretation Act defines "Canada" to mean: ".....the territory of Canada, and includes (a)     every area beyond the territorial seas of Canada that, in accordance with international law and the laws of Canada, is an area in respect of which Canada may exercise rights with respect to the sea bed and subsoil and their natural resources, and (b)     the seas and airspace above every area described in paragraph (a);" As you can see from these definitions, Canada is not limited to a specific number of miles offshore. ...

Income Tax Convention (1980) this rate is not reduced. Is a Canadian payer of royalties (e.g a "production royalty" as defined in section 1206 of the Regulations) required to withhold Part XIII tax on the basis of the cash royalties or on the basis of the gross royalties before the deduction of mineral tax or other Crown charges paid by the recipient in respect of such royalties? ...

La position du Ministère concernant l'impact d'une convention entre actionnaires sur la détermination de la JVM des actions d'une société est exposée dans la circulaire d'information 89-3 et dans le bulletin d'interprétation IT-140R3. ...

Income Tax Convention, the Department is reconsidering its administrative position with respect to single purpose corporations. ...

Income Tax Convention This is in reply to your letter dated June 8, 1994 regarding the application of the above provisions to the following hypothetical situation. ...