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Then, in some cases, all or a portion of the foreign pensions may be exempt from Canadian tax by virtue of a provision contained in an income tax convention ("tax treaty") that Canada has with another country. ...

Tax Convention, the withholding rate is reduced to 15% but only in respect of periodic pension payments. ...

Canada has not entered into an income tax convention with Guinea. As such, there is no relief from withholdings available under a treaty. ...

The effect of subsection 212(11) (subject to the exemptions in subsections 212(9) and (10)) is that amounts received from a trust by a non-resident that, if they had been received directly by the non-resident would have been exempt from Part XIII tax, will nonetheless be subject to the withholding tax under paragraph 212(1)(c), subject to any exempting provisions of a tax convention. ...

Income Tax Convention Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

There is no relief under the Canada-Belgium Tax Convention in respect of pension payments to a resident of Belgium which are subjected to tax under paragraph 212(1)(h) of the Act. ...

Income Tax Convention. You have also requested our opinion as to whether this position applies to the surrender of a capital interest in a trust resident in 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) as is designated by the taxpayer in the taxpayer's return of income under Part I of the Act for the year. ...

However, in our view both the compensatory payment and the lending fee would either be subject to tax pursuant to subparagraph 212(1)(d)(i) of the Act for 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) assuming the lender to be a US resident. ...

Income Tax Convention on their share of income of the limited partnerships which is not attributable to a permanent establishment of the partnerships in the U.S. ...