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Income Tax Convention We are writing in response to your email dated May 15, 2020, requesting our views on the interpretation of the phrase “such use is for more than three months in any twelve-month period” contained in Article V(4) of the Canada-U.S. Income Tax Convention (the “Canada-U.S. Treaty”). In particular, you requested our views as to whether the term “three months” refers to a consecutive period, whether “three months” means three calendar months or days totaling an equivalent of three months, and whether the word “use” includes standby time and preparation time. ...

Wilson  Division 957-2063 Attention:  Ken Major File No. 90M02429 Chief, Foreign Section 24(1)- SECURITY LENDING REVENUE CANADA- UNITED KINGDOM INCOME TAX CONVENTION We are writing in regard to an interpretation of Article XI, sub-paragraph 4(a) and paragraph 5 of the above-noted treaty.  24(1) has requested confirmation as to the tax treatment of income received by the 24(1) as compensation for Canadian Government Bonds loaned pursuant to a securities lending arrangement. 24(1) is of the opinion that the treaty exempts this income from Part XIII tax (copy of letter attached). ...

19 April 2012 Internal T.I. 2012-0436221I7- LLCs and ULCs and Treaty benefits Unedited CRA Tags Articles IV(6) and IV(7) of the Canada-United States Income Tax Convention Principal Issues: 1. Whether a single member limited liability company ("LLC") created pursuant to the laws of the United States (“U.S.”) which is treated as a disregarded entity for U.S. tax purposes, is entitled to the benefits of the Canada-United States Income Tax Convention ("Treaty")? ... April 19, 2012 Janet Schermann HEADQUARTERS Non-Resident Policy Advisor Income Tax Rulings 112 Kent St., room 1929 Directorate Place de Ville, Tower B Angelina Argento Ottawa, Ontario, K1A 0L5 2012-043622 Limited liability company ("LLC"), unlimited liability company (“ULC”) and the Canada-United States Income Tax Convention ("Treaty”) This is further to your email request of February 9, 2012 wherein you asked for suggested wording to be added to the CRA website which would address the following issues: 1. ...

Internal Revenue Code (Inverted Payer Corporation) to: a. a corporation resident of the US that is entitled to treaty benefits under the Canada-US Income Tax Convention (Treaty); b. another Inverted Payer Corporation (incorporated in Canada); c. a Canadian resident taxpayer; d. a resident of a country other than Canada or the US (without regard to any applicable treaty provisions). 2. ... Angelina Argento Compliance Programs Branch 2022-093626 Application of the Canada-US Income Tax Convention to expatriated entities This is in response to your request for a technical interpretation dated May 13, 2022, wherein you requested our views on the Canadian withholding obligations in respect of certain amounts paid or credited by a corporation incorporated under the laws of Canada that is subject to the so-called “anti-inversion rules” set forth in §7874(b) of the Internal Revenue Code of the United States of America (Inverted Payer Corporation) (footnote 1). ... That rate may be reduced by the provisions of an Income Tax Convention between Canada and the country of residence of the recipient of the Payments. ...

Power   FILE 903359             SUBJECT:     Offshore Activities Article Canada-Netherlands Income Tax Convention We are writing in reply to your memorandum dated November 22, 1990, in which you requested our comments concerning the offshore activities article in the above-noted treaties. ... Income Tax Convention (U.K. Treaty) Questions: 1.     What would be considered "activities" for purposes of paragraph 2 of Article XXVIIA of the U.K. ... Article 23 of the Canada-Netherlands Income tax Convention (Dutch Treaty) Questions 1.      ...

For Japanese tax purposes, XXXXXXXXXX computed its income from carrying on business in Japan in accordance with the provisions of Article 7 of the Canada-Japan Income Tax Convention (the "Convention"). ... As a result, for FTC purposes more income was sourced to the Japanese permanent establishment than was reported in Japan as directed by the Convention. ... However, it used the CCRA's approach both in determining its profits for the purposes of the Convention and for accounting purposes. ...

Income Tax Convention (1980)(the "Treaty") This memorandum is in response to yours of June 27, 1989 in which you requested our opinion concerning the characterization of property as real property situated in Canada which, upon alienation by a resident of the United States, can result in a taxable gain in Canada pursuant to Article XIII of the Treaty. ...

Income Tax Convention ("Treaty") We are responding to your email of June 24, 2013 wherein you ask whether interest (which is "participating debt interest" within the meaning of subsection 212(3) of the Act because it is calculated with reference to commodity price; specifically the index value of oil and gas), paid by a corporation resident in Canada ("Canco") to a resident of the US (which is a "qualifying person" within the meaning of Article XXIX-A of the Treaty), is subject to 15% Canadian withholding tax pursuant to subparagraph 6(b) of Article XI of the Treaty? ...

Senécal   (613) 957-2074   HBW 4215-I7 November 2, 1989 Dear Ambassador: We would like to take this opportunity to send you further documentation dealing with the recent amendments to the Canada- Italy Tax Convention as they pertain to the tax treatment of pensions paid by the Italian Government to residents of Canada.  ...

Income Tax Convention (1978) provides no such relief. In the event the above information does not satisfy your requirements, we would be prepared to review a more specific enquiry detailing the residency status of the employee, complete information concerning the plan involved, etc. ...