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Le XXXXXXXXXX a conclu, à titre d'acheteur, une convention d'achat d'actions (Convention I) avec XXXXXXXXXX (Vendeur I), à titre de vendeur; 2. ... Le terme "Pertes" est défini au paragraphe XXXXXXXXXX de la convention. ... Le terme "Pertes" est défini au paragraphe XXXXXXXXXX de la convention de la même façon qu'à la Convention I du XXXXXXXXXX; 10. ...

(2) Si oui, l'article 28(3) de ladite convention applicable aux sociétés holding ou à des sociétés soumises au Luxembourg à une législation fiscale similaire s'applique-t-il de façon à nier aux SICARs (et à leurs investisseurs canadiens) les bénéfices de la Convention? ... La position de l'ARC sur la question de la résidence aux fins des conventions fiscales a été réitérée dans la Nouvelle Technique no 35 Résidence aux fins d'une convention fiscale- Résidence de complaisance, publiée le 26 février 2007. ... En ce sens, nous sommes d'avis que l'article 28(3) de la Convention doit s'appliquer afin de nier aux SICARs et à leurs investisseurs canadiens les bénéfices de la Convention. ...

XXXXXXXXXX January 30, 2004 Income Tax Appeals Division Sophie Chatel 333 Laurier Avenue West Ottawa ON K1A 0L9 Attention: Janine Dunphy 2004-005498 Social Security Payments under the Canada-Cyprus Convention- Article 18 This is in reply to your enquiry of January 6, 2004 wherein you requested our views on application of the Canada-Cyprus Convention (the "Convention") in respect of payments under Canada's social security system. ... Paragraph 5 of Article 18 of the Convention provides that social security pensions arising in Canada and paid to a resident of Cyprus are only taxable in Canada. ... Moreover, paragraph 1 of the Convention also provides that the first CND$10,000 of pension payments (periodic payments or lump sum payments) are exempt from tax in the country in which they arise. ...

Income Tax Convention. Position: Yes, in the situation described in the memo. Reasons: Because Article XXIX B of the Convention only applies to the year of death. ... Income Tax Convention (the "Convention") We are writing to reply to your request for our comments on a statement made by your client with respect to the interaction of subsection 104(4)of the Act and paragraph 6 of Article XXIX B of the Convention. ...

Therefore, the Convention removes the obligation of a Canadian resident to pay U.S. income tax in excess of the amount that would have been paid under the Convention. ... The result would be the same if the taxpayer opts out of the Convention. ... AMT arises in spite of the Convention not because of the Convention. Example E (Canadian Source Income with Some U.S. ...

Therefore, the Convention removes the obligation of a Canadian resident to pay U.S. income tax in excess of the amount that would have been paid under the Convention. ... The result would be the same if the taxpayer opts out of the Convention. ... AMT arises in spite of the Convention not because of the Convention. Example E (Canadian Source Income with Some U.S. ...

17 February 2014 Internal T.I. 2013-0498121I7- Follow up to XXXXXXXXXX CRA Tags Vienna Convention on Diplomatic Relations Article 39 162(7) Vienna Convention on Diplomatic Relations Article 34 Principal Issues: Is a diplomatic agent exempt from a penalty under 162(7) as a result of filing a notice of disposition late? ... February 17, 2014 Legislative Policy Directorate HEADQUARTERS Legislative Policy and Regulatory Income Tax Rulings Affairs Branch Directorate Attention: France Marengère Katharine Skulski (613) 957-8585 2013-049812 Vienna Convention We are writing in reply to your request for our comments regarding whether the Vienna Convention on Diplomatic Relations (the "Convention") would exempt a diplomatic agent and/or his child from liability for a penalty under subsection 162(7) of the Income Tax Act (the "Act"). ... For the same reasons, the convention would not exempt the child from taxes. ...

Income Tax Convention (the "Convention") Position: The lesser of the two amounts described in (a) and (b) of subsection 227(6.1) Reasons: The law is very specific in this regard. ... Income Tax Convention (the "Convention") We are writing in response to your memorandum of May 6, 1997 in which you requested our interpretation of subsection 227(6.1) of the Income Tax Act (the "Act") in determining the amount of refund payable to a non-resident person on repayment of a shareholder's loan in respect of which Part XIII tax has previously been paid pursuant to paragraphs 214(3)(a) and 212(2)(a) of the Act. ... The change in the tax rate may either be caused by an amendment to Article X (Dividends) of the Convention with respect to the tax rate or by a change in the percentage of ownership of the voting stock of a company described in paragraph 2 of Article X of the Convention. ...

Tax Convention (where the individual is not in Canada for more than 183 days)? ... Kreuger: Re: Application of Paragraph 2 of Article XV of the Canada-United States Income Tax Convention (the "Convention") to an Employee Stock Option Benefit This is in reply to your email letter to us of March 4, 2002 (the "Email Letter"), in which you asked us to consider the application of paragraph 2 of Article XV of the Convention to the following situation:? ... The taxpayer was a resident of the United States for purposes of the Convention.? ...

Therefore, the Convention removes the obligation of a Canadian resident to pay U.S. income tax in excess of the amount that would have been paid under the Convention. ... The result would be the same if the taxpayer opts out of the Convention. ... AMT arises in spite of the Convention not because of the Convention. Example E (Canadian Source Income with Some U.S. ...