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Convention Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Convention. Reasons: Taxpayer resident of U.S. for purposes of the Convention. ... As set out in the Technical Notes to the Convention, the term "borne by" in the context of Article XV of the Convention means an amount deducted from income for tax purposes. ...

It is not a "qualifying person" for the purposes of paragraph XXIX-A(1) of the Convention. 6. ... In general terms, Article XXIX-A of the Convention states that a person that is a resident of a Contracting State and that is not a "qualifying person" may nonetheless be entitled to the benefits of the Convention if one of three exceptions applies. Paragraph XXIX-A(3) of the Convention provides for one of these exceptions. ...

The provisions for taxing business income are found in Article 7 of the Convention. ... Valuable guidance on the interpretation of articles within income tax conventions is provided in the commentary to the OECD Model Tax Convention on Income and Capital (July 2010). ... The definition of "immovable property" is found in paragraph 2 of Article 6 of the Convention. ...

Income Tax Convention (the “Convention”) but the U.S. tax so imposed should not exceed certain tax rates provided by the Convention (the “treaty rate(s)”). ... Before the Third Protocol, paragraph 5 of Article XXIV of the Convention required that Canada provide a tax credit equal to the lesser of the amount of U.S. tax otherwise payable or 15% of the gross amount of each item of income referred to in that paragraph regardless of the rate that such item of income was taxed by the U.S. under the Convention. ... In the mean time if the tax imposed by the U.S. after tax credits on an item of income referred to in paragraph 5 of Article XXIV of the Convention as amended by the Third Protocol exceeds what is allowed under the Convention, you may suggest the taxpayer to seek the assistance of Competent Authority in Canada to resolve the issue. ...

Income Tax Convention (the “U.S. Convention”) This is in reply to your memorandums of April 24th and 30th in which you requested clarification as to whether the provisions of paragraph 2(a) of Article XXI of the U.S. ... Convention, income referred to in Article X (Dividends) and XI (Interest) of the U.S. ... Convention, this would depend on the actual facts surrounding each particular payment. ...

Tax Convention (the "U.S. Convention") and the resident of the second country is entitled to benefits under Canada's treaty with the second country. ... The LLC is owned one-third each by a U.S. resident, a resident of another country with which Canada has an income tax convention, and a resident of a third country with which Canada does not have an income tax convention. ... Tax Convention, we would not be opposed if you took the view, administratively, that the purchaser may file a T2062C Notice in respect of the LLC. ...

Articles 1, 22 to 24 and 27 to 40 of the Vienna Convention on Diplomatic Relations (the "Diplomatic Convention"); and? ... A by Article 34 of the Diplomatic Convention. For example, there is nothing in Article 34 of the Diplomatic Convention that is dependent on the residency status of the diplomatic agent for purposes of the Act. ... Pursuant to Article 34 of the Diplomatic Convention, Mr. A is subject to tax in Canada on a limited basis; and in particular, under paragraph 34(d) of the Diplomatic Convention, Mr. ...

Income Tax Convention (the Convention) even where all the members of the LLC are residents of U.S. for the purposes of the Convention. ... An LLC is not considered to be resident of the U.S. for the purpose of the Convention. ... Even if a LLC was a resident of the U.S. for the purposes of the Convention, the above position would not result in taxation that is contrary to the Convention. ...

Income Tax Convention March 3, 1997 R. Léger International Section Director S. ... Income Tax Convention (the "Convention"), U.S. tax is limited to 15% of the gross amount of such income. ... It should be noted that paragraph 2 of Article XXIX of the Convention shall not, by virtue of paragraph 3 of that Article, affect the obligations undertaken by the U.S. under Article XXIV of the Convention. ...

Reasons: Application of Article 19 of the Convention and review of status as employee or student. ... Ottawa, ON K1A 1A8 + + FILE DOSSIER 2004-007608 SUBJECT: OBJET: Article 19 of the Canada-China Income Tax Convention (the "Convention") We are writing in reply to your memorandum to us of May 10, 2004, regarding the above-noted subject matter. ... It is not clear whether the taxpayer was a resident of China for purposes of the Convention immediately prior to arriving in Canada.? ...