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3 January 2001 Internal T.I. 2000-0024247- Section 6.2 of Income Tax Convention-- summary under Section 6.2 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 6.2 Article 20 of the Canada-New Zealand Convention provides that items of income of a resident of New Zealand which are not dealt with in other Articles and which are derived by the resident from sources in Canada may be taxed in Canada according to the laws of Canada. A gain of a resident of New Zealand from a disposition of shares of a private Canadian corporation that were taxable Canadian property was subject to Canadian capital gains tax given that it had been the intention of the Canadian negotiators of Canadian ncome tax conventions that the source of income on a disposition of taxable Canadian property is from Canada and this intention was confirmed, for greater certainty, by s. 6.3 of the Income Tax Convention Act. ...

3 January 2001 Internal T.I. 2000-0024247- Section 6.2 of Income Tax Convention-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Article 20 of the Canada-New Zealand Convention provides that items of income of a resident of New Zealand which are not dealt with in other Articles and which are derived by the resident from sources in Canada, such income may be taxed in Canada according to the laws of Canada. A gain of a resident of New Zealand from a disposition of shares of a private Canadian corporation that were taxable Canadian property was subject to Canadian capital gains tax given that it had been the intention of the Canadian negotiators of Canadian Income Tax Convention that the source of income on the disposition of taxable Canadian property is from Canada and this intention was confirmed, for greater certainty, by s. 6.3 of the Income Tax Convention Act. ...

Income Tax Convention-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Where a decision was made with respect to an interest-bearing obligation of a company that the interest due and payable for that year would not be paid, the unpaid interest represented a new obligation for purposes of the exemption in paragraph 3(e) of Article XI of the Canada-U.S. Convention, with the result that interest on such amount was not grandfathered under that provision. ...

14 April 2014 Internal T.I. 2013-0516151I7 F- Article XIII(4) of the Canada-XXXXXXXXXX Convention-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 partnerships holding Quebec real estate were transparent for purposes of Treaty "consists of" test A non-resident corporation (Vendor) disposed at a gain of shares of Canco, which held partnership interests in two Quebec real estate partnerships (an SEC and SENC). ... XIII, para. 4 of the Canada-Singapore Convention, on the basis that para. 3 did not apply, which refers to: gains from the alienation of shares of a company, or of an interest in a partnership or a trust, the property of which consists principally of immovable property…. ... [T]he better position…is to consider that SEC and SENC are not distinct persons for purposes of the Convention and that their respective patrimonies can be assimilated to that of their members. ...

24 March 2016 Internal T.I. 2016-0634191I7- Income from a U.S. trust-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions all U.S. ...

10 January 2014 Internal T.I. 2013-0505911I7- Meaning of "assembly project" in Brazil Convention-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "assembly" and "installation" project Art. ...

29 March 2006 Internal T.I. 2006-0171171I7 F- Convention de retraite-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement plan was not an RCA because benefits were unreasonable A plan set up to provide benefits to officers of a corporation was not a retirement compensation arrangement (RCA) since the benefits to be paid were not reasonable in the circumstances. ...

2 May 2001 Internal T.I. 2001-007939 F- CONVENTION D'EMISSION D'ACTIONS-- summary under Subsection 7(2) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(2) whether s. 7(2) applied turned on whether shares were held as trustee After providing an overview of s. 7(2), the Directorate noted that in this case whether it applied turned on a factual determination of whether shares were held by a person as trustee. ...

29 March 2006 Internal T.I. 2006-0171171I7 F- Convention de retraite-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 application of a version of the Gabco test Amounts paid to a trust governed by a retirement compensation arrangement (RCA) were non-deductible in computing the corporation's income on the basis that the amounts paid were not paid to earn income and were not reasonable in amount. ...

18 May 2011 Internal T.I. 2010-0380391I7 F- Convention entre des co-propriétaires-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income agreement of co-owners to share revenues disproportionately would be recognized if such agreement is binding Two co-owners of a triplex (the “Taxpayers”) agree that the first Taxpayer can live in one of the units free of rent and that the other Taxpayer, whose daughter resides in a second unit, would be exclusively allocated for inclusion in that Taxpayer’s return all the revenues generated by that unit. ...