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13 October 2020 External T.I. 2020-0860081E5- Pension income from India-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 a military pension form India was Treaty-exempt Would the receipt by a Canadian resident of a military service pension and a military disability pension from the Ministry of Defence of the Government of India be taxable? ...

10 February 2022 External T.I. 2019-0819651E5 F- Pension from China-- summary under Article 19 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 19 pension from China paid to former civil servant now resident in Canada was not exempted under Art. 18 of the Canada-China Treaty A Canadian resident who had retired from the civil service of the State of China received a pension that was not taxable under the domestic tax law of China. ...

XIII(3) of the Canada-US Convention, as that provision was not yet in force. ...

CRA replied that the OECD Model Convention provides that a fee for the use of computer software is not characterized as a royalty for treaty purposes, and stated that such a fee would not be a royalty unless the bilateral tax treaty in issue "includes an intellectual property clause specifically providing that payments for digital property are considered taxable as a royalty. ...

XII of the Canada-US Income Tax Convention): In general, payments made to a non-resident for information concerning industrial or commercial experience fall within subparagraph 212(1)(d)(ii) of the Act.... ...

Where the individual's services are exclusively performed in Canada, the entire benefit will be sourced to Canada based on the allocation method set out in Annex B to the 5th Protocol to the Canada-US Convention. ...

17 October 2012 External T.I. 2012-0438671E5- Treatment of German social security pension-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Discussion of treatment of German social security pensions including link to discussion at www.cra-arc.gc.ca/tx/nnrsdnts/ntcs/grmny2005-eng.html. ...

XV of Canada-France Convention, as not being in respect of employment exercised in Canada, or Art. ...

23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 non-application of Art. 12 of US Treaty to resource royalties Mr. ...

.-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 SIFT distributions respected as dividends An IRA account of Mr. ...