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Income Tax Convention (the "Treaty"). Under paragraph 1 of Article VII of the Treaty, the business profits of a resident of the United States are only taxable there if the resident has no permanent establishment in Canada. ...

Income Tax Convention (1980) if the amount of the gross receipts received in the calendar year by the U.S. resident athlete from Canadian sources is less than $15,000. ...

Canco garantit ces biens contre tout défaut de fabrication. 2.Canco détient 100 % des actions émises et en circulation d'une société étrangère affiliée contrôlée (SEAC) selon le sens donné à cette expression au paragraphe 95(1) de la Loi, résidant dans un pays avec lequel le Canada a conclu une convention fiscale 3.Si les produits vendus aux clients à l'extérieur du Canada nécessitent des réparations en raison d'un défaut de fabrication, SEAC utilise son propre personnel et son propre matériel pour faire ces réparations. ...

Income Tax Convention (1980) has been forwarded to our Foreign Section for its consideration. ...

The expression "flow-through share" has the meaning assigned by subsection 66(15) of the Income Tax Act (the "Act") and the expression "permanent establishment" has the meaning assigned by Article V of the Canada-United States Income Tax Convention, 1980 as amended by the protocols signed on June 14, 1983, March 28, 1994, and March 17, 1995 (hereinafter referred to as the "Treaty"). ...

Income Tax Convention, and was not subject to an income or profits tax in the U.S. or any other country to which the treaty does not apply, no amount of the gain would be included in the computation of "qualifying incomes". ...

All of the US controlled foreign affiliates of Canco are residents of the US and would be considered US residents pursuant to the Canada-US Income Tax Convention. 5. ...

All of the US controlled foreign affiliates of Canco are residents of the US and would be considered US residents pursuant to the Canada-US Income Tax Convention. 5. ...

With respect to how Article 15 of a tax treaty might apply, we note that it may be helpful to you to review the Commentary to the OECD Model Tax Convention for Article 15. ...

We assume that none of the dispositions in the Canada-United States Income Tax Convention prevents Canada from taxing this salary. ...