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25 June 2012 External T.I. 2011-0404071E5- Election to defer income in U.S. traditional IRA-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 It is unnecessary for a Canadian-resident individual to file an election under Art. XVIII(7) of the Canada-US Convention to defer recognition of income on investments in a US Individual Retirement Account because the Act already provides such deferral: Under clause 56(1)(a)(i)(C.1) of the Act, an individual is required to include amounts under a foreign retirement arrangement in income only when the amounts are paid out of the plan. ...

17 February 1997 External T.I. 9625935- SOURCE OF CANADIAN TRUST INCOME RE ART XXI(6)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Where a trust resident in Canada has made a designation under s. 104(22) with respect to U.S. ... Convention, given that s. 104(22) recharacterizes the income only for limited purposes. ...

TREATY-- summary under Rules Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27A- Rules Re application of paragraph 4 of Article 27 of the Canada-U.K. Convention where a share of a U.K. corporation held by a resident of Canada is purchased for cancellation. ...

TREATY-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Re application of paragraph 4 of Article 27 of the Canada-U.K. Convention where a share of a U.K. corporation held by a resident of Canada is purchased for cancellation. ...

(U4-100-17)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 A payment out of a RRIF is considered to be a payment under a retirement plan referred to in the definition of pension in Article 17, paragraph 3, of the Canada U.K. ... If the payment from the RRIF qualifies as a periodic pension payment as defined in s. 5 of the Income Tax Conventions Interpretation Act, it would fall under the meaning of pension in Article 17 and would be exempt from Canadian non-resident withholding taxes pursuant to paragraph 1 of Article 17. ...

TREATY-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 "As long as the amount of the pension arising in the U.S. would have been excluded from taxable income in the U.S. by a U.S. resident recipient, such amount would be exempt from taxation in Canada by a Canadian resident recipient. ... -Canada] Convention...." A taxpayer who receives a periodic pension from the International Monetary Fund should file a letter from the IMF annually with his or her T1 return. ...

PENSION RECEIVED BY CANADIAN (4093-U5-100-18)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 In order for RC to grant treaty-exemption for the portion of U.S. pension benefits paid to a Canadian resident that represent a return of premiums, it will require a breakdown from the plan. ... Convention. ...

1 March 1995 External T.I. 9426805- WITHHOLDING TAX ON INTEREST (HAA 4093 U5-100-11)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The exemption in the post-1994 version of paragraph 3(d) of Article XI of the Canada-U.S. Convention would apply to exempt interest paid by a Canadian resident on a U.S. dollar credit card issued by a Canadian financial institution where that institution had agreed with a U.S. bank that the U.S. bank would reimburse U.S. merchants for purchases made by the customer in the U.S.; the Canadian financial institution assigned to the U.S. bank all receivables due to it arising from such use of the card; and the cardholders made all payments with respect to their account balances directly to the U.S. bank. ...

10 March 1995 External T.I. 9506415- CAPITAL GAINS- CANADA-AUSTRALIA TREATY (HAA-4093-A3-100)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Where a corporation which is resident in Australia realizes a gain on the disposition of shares of a corporation resident in Canada, the phrase "items of income" in paragraph 1 of Article XXI of the Canada-Australia Convention will include such gain even if it is realized on capital account rather than income account. ...

8 January 1996 External T.I. 9428025- RETURN OF CAPITAL FROM A DELAWARE CORPORATION-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Because the purpose of the "source country deemed dividend rule" in the definition of "dividend" in paragraph 3 of Article X of the Canada-U.S. Convention is only "to ensure that the source country's right to tax an amount that would not otherwise meet the definition of a 'dividend', but is treated as such in the source country, will be governed by paragraph 2 of Article X", that rule does not trammel the ability of Canada to tax as a dividend a distribution received by Canadian-resident shareholders of a Delaware corporation that might not be treated like a dividend under the U.S. ...