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Une attention particulière doit aussi être porté à l'article XVIII(5) de la Convention fiscale de 1980 entre le Canada et les États-Unis à l'égard de ce type de paiement. ...

The determination of whether a particular income tax convention would affect the application of the above provisions of the Act can only be determined on a case by case basis where all of the facts are known. ...

Income Tax Convention (1980). If you require assistance in applying the tiebreaker rules under the treaty, we would be pleased to provide our comments. ...

Income Tax Convention (the "Treaty"). In short, per Article 17 of the Treaty, pension payments arising in Canada and paid to U.K. residents are not taxable in Canada unless they are "any payment under a superannuation, pension or retirement plan in settlement of all future entitlements under such a plan". ...

Income Tax Convention (1980) unless the shares are described in subparagraph 3(b)(ii) thereof. ...

Taxpayers should be advised to refer to any relevant bilateral income tax conventions which may have application. ...

Tax Convention. 4.     In Year 4 Canco agrees to waive its right to repayment of the loan. ...

Mackintosh Computers Ltd. and Apple Computer Inc. v. 115778, what is Revenue Canada's position with respect to the application of paragraph 212(1)(d) of the Act and the Canada-U.S Income Tax Convention (1980) to payments made by a resident of Canada to a U.S. resident owner of a computer program in respect of the production or reproduction of the program? ...

Tax Convention (the “Treaty”), no foreign tax credit would be available in respect of U.S. withholding tax on the distributions (absent another source of qualifying income in the U.S.). ... Paragraph 3 of Article XXIV provides that profits income or gains … which may be taxed in the other Contracting State in accordance with the Convention … “shall be deemed to arise in that other Contracting State”. ...

Also, the amount received by the Individual would have to be included in his income for the year under subparagraph 56(1)(a)(i) unless a provision of the income tax convention between Canada and the other country applies to exclude the amount from income. However, Canada does not have a tax treaty with Hong Kong and Canadian courts have confirmed that the income tax convention between Canada and China does not apply to Hong Kong. ...