Search - convention

Individual Savings Account (ISA)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Although income earned in a UK Cash ISA is not subject to taxation in the U.K., under the Canadian Income Tax Act ("Act") Canadian residents... must report their worldwide income, including income earned on investments held in the U.K., for Canadian tax purposes. ... CRA also indicated that neither Article 11 nor Article 17 of the Canada-UK Convention would apply to relieve taxation. ... XVIII of the Canada-US Convention.) ...

Individual Savings Account (ISA)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Although income earned in a UK Cash ISA is not subject to taxation in the U.K., under the Canadian Income Tax Act ("Act") Canadian residents... must report their worldwide income, including income earned on investments held in the U.K., for Canadian tax purposes. ... CRA also indicated that neither Article 11 nor Article 17 of the Canada-UK Convention would apply to relieve taxation. ... XVIII of the Canada-US Convention.) ...

28 April 2010 External T.I. 2009-0347581E5 F- Frais de formation-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) convention expenses providing an enduring benefit may be deducted within the s. 20(10) limitations When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible, CRA stated: Training costs are not deductible as current expenses and are considered to be capital expenditures under paragraph 18(1)(b) if the training course to which they relate provides a lasting benefit to the taxpayer. … As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ... In addition, a convention does not become a training course when some of its sessions take the form of workshops. Although convention expenses may provide a lasting benefit to the taxpayer, the taxpayer may deduct these expenses in computing income under subsection 20(10), subject to the limitations contained in that subsection. ...

25 May 2004 External T.I. 2003-0051291E5 F- Formation et croisière-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) costs of cruise, if not viewed as training, would be non-deductible as they were incurred outside Canada Are expenses incurred by members of an Association respecting conventions, symposia and seminars held during a cruise deductible from their income? CRA noted that IT-357R2, para. 9 indicates that training is aimed at learning a subject in accordance with a formal course of study, whereas a convention is a formal meeting of members of an organization for professional or business purposes. ... CRA then stated: Assuming that the expenses [instead] are incurred in connection with a convention held during a sea cruise, it is our view that no amount for expenses incurred to attend the convention would be deductible since the convention would be held outside the geographical boundaries of the association that is the sponsor of the convention, as discussed in paragraph 2 of IT-131R2. ...

7 April 2006 External T.I. 2005-0132981E5 F- Avantages imposables à des employés-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) meaning of convention Does a convention for s. 20(10) purposes include a symposium, conference, information session or formal meeting? CRA responded: [A]s stated in … IT-131R2 [para. 1] a convention may be defined as a formal meeting of members of an organization for professional or business purposes. Words and Phrases convention ...

Expense- Know-How and Training distinction between training and convention expenses/ luncheon seminar fees on case law generally are professional deductions When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible, CRA stated: Training costs are not deductible as current expenses and are considered to be capital expenditures under paragraph 18(1)(b) if the training course to which they relate provides a lasting benefit to the taxpayer. ... As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ... In addition, a convention does not become a training course when some of its sessions take the form of workshops. ...

12 March 2003 External T.I. 2002-0176955 F- Retenu dividende français-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Canadian mutual fund trust or pension fund trust deemed to be the beneficial owner of dividends by Art. 29(7)(a) of the Canada-France Convention CCRA indicated, regarding whether a dividend paid by a French corporation to a Canadian mutual fund trust or Canadian pension fund would be reduced pursuant to Art. 10(2)(c) of the Canada-France Convention, that assuming that such funds were resident in Canada as defined in Art. 4(1), any doubt as to whether they were the beneficial owners of the dividends would appear to be eliminated by Art. 29(7)(a) of the Convention. ...

Convention A Canadian resident employee, after qualifying for benefits under the unfunded long term disability plan ("LTD Plan") of the Canadian resident employer, becomes a resident of the U.S. ... While the LTD plan payments would be taxable as income from employment for purposes of the Act, such income would be considered as being pension income for the purposes of applying the provisions of the Convention. ... Consequently, one must refer to the provisions of Article XVIII of the Convention rather than those of Article XV (Income from Employment)…. ...

11 July 2006 External T.I. 2006-0182451E5 F- Indemnité versée par un syndicat-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) payments by union to members to attend union conventions on their days off not taxable In order to encourage members to participate in union activities on their day off, the union compensates them during their attendance at union councils or conventions where matters such as working conditions, training, pressure tactics if necessary, and the general administration of the union are discussed. CRA stated: [W]here the member who attended the conventions is not employed by the union and the member does not carry on a business in the course of which the member receives those amounts, the amounts the member receives as compensation for attending union councils or conventions on their days off would not be derived from a source of income and would not be taxable. ...

31 January 2006 External T.I. 2005-0151041E5 F- Régimes de sécurité sociale étrangers-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 plan recognized as a pension plan under Art. 29(5) of the Cda-France Convention cannot be an EBP In response to a query as to whether contributions made by an employer to certain French social security plans are considered taxable benefits to employees who are residents of Canada for a period not exceeding 5 years and an expressed view that such plans are employee benefit plans ("EBP") so that no amount is to be included in the employee's income as a benefit under s. 6(1)(a)(ii), CRA stated: [W]here a pension plan is recognized for the purposes of paragraph 5 of Article 29 of the [Canada-France] Convention, it is our view that it is not an EBP. ... The CRA summary further noted: The Tax Convention takes precedence over the application of the Act. ...