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From the Perspective of the Canada-United States Income Tax Convention (a) An Agreement between Two Federal Governments Only The Convention is an agreement between the Government of Canada and the Government of the United States of America. ... Therefore, taxes referred to in the Convention generally mean federal income taxes unless it is stated otherwise in a provision of the Convention. ... It is therefore apparent that provincial taxes are not taken into consideration in paragraph 6 of Article XXIX B of the Convention. ...

Income Tax Convention (the "Convention") removes the basic withholding tax exemption granted under that Article where the income is derived from a "related person". ... Department's Position The term "related person" is not defined in the Convention. ... In the context of Article XXI of the Convention "related person" has the meaning assigned in the Act. ...

However, amount would likely be pension for purposes of Convention. Reasons FOR POSITION TAKEN: Periodic pension supplement paid by employer would be a pension for purposes of the Convention even though it may be a retiring allowance and not a pension for purposes of the Act. ... Income Tax Convention (1980) (the "Convention") to a pension supplement he is receiving from his former employer, XXXXXXXXXX (the "Employer"). ... For the purposes of the Convention, the term pension includes any payment under a pension plan. ...

Income Tax Convention. June 26, 2002 HEADQUARTERS HEADQUARTERS Registered Plans Directorate Income Tax Rulings Directorate Attention: Mike Godwin G. ... Income Tax Convention ("Convention")). Pursuant paragraph 3 of Article 18 of the Convention, the term "pensions" includes any payment under a superannuation, pension or other retirement arrangement, Armed Forces retirement pay, war veterans pensions and allowances and amounts paid under a sickness, accident or disability plan, but does not include payments under an income-averaging annuity contract or any benefit under the social security legislation of either Canada or the United States. ... For example, RCAs which provide for retiring allowances or death benefits would not be "pensions" for purposes of the Convention. ...

Income Tax Convention (1978)? Position: No. Reasons: We have previously taken the position that such an amount would constitute a payment in settlement of all future entitlements in respect of the $XXXXXXXXXX and, as such, would not meet the definition of pension in paragraph 3 of Article XVII of the Convention. ... Income Tax Convention (1978) (the "Convention"). The individual argued that the $XXXXXXXXXX qualified under paragraph 1 of Article XVII of the Convention because it did not represent a payment under a superannuation, pension or retirement plan in settlement of all future entitlements under the DPSP. ... Comments In our opinion, the lump-sum withdrawal of $XXXXXXXXXX from the DPSP represents a settlement of all future entitlements in respect of the $XXXXXXXXXX previously held in the DPSP as contemplated by paragraph 3 of Article XVII of the Convention, and is, therefore, not a "pension" for purposes of paragraph 1 of Article XVII of the Convention. ...

Income Tax Convention (1980) (the "Convention") in the context of the following set of hypothetical facts: 1.      ... Accordingly, paragraph 2 of Article XI of the Convention would give Canada the right to tax such interest. However, the rate of 25% otherwise withheld under subsection 212(1) of the Act would be reduced to 15% by Article XI of the Convention. ...

Position: The Public Lending Right Program payments fall under Article 14 of the Canada-Ireland Income Tax Convention. ... In summary, we agree that the appropriate characterization of the PLRP payment for purposes of the Convention is income derived in respect of professional services or other activities of an independent character, specifically independent literary or artistic activities, and that this income falls under Article 14 of the Convention. ... Paragraph 2 of Article 14 of the Convention defines "professional services" to include independent literary and artistic activities. ...

Cette cotisation a été faite en considérant l'alinéa 2(a) de l'article XV et l'alinéa 4(a) de l'article XXIV de la Convention fiscale entre le Canada et les États-Unis (la Convention). 4.       ... Donc, en vertu du paragraphe 2 de la Convention, ce revenu n'est pas imposable aux États Unis. Les dispositions du paragraphe 2 de l'article XXIX de la Convention permettent (sous réserve de certaines dispositions de la Convention mentionnées au paragraphe 3) à un État contractant, soit le Canada ou les États-Unis, d'imposer ses résidents (et dans le cas des États Unis ses citoyens) comme si aucune Convention n'existait entre les deux États contractants. ...

No 3. yes in all conventions except the present Luxembourg convention Reasons: 1. ... Pay equity interest (and refund interest) fall under the meaning of "interest" in the income tax conventions ("conventions") that Canada has entered into with other countries and the payments of such interest amounts to individuals are usually dealt with under the Interest Article in the conventions. ... We have not reviewed the Interest Article provisions in Canada's other conventions. ...

Furthermore, section 18 of Article V of the Convention on the Privileges and Immunities of the United Nations ("Convention") provides exemption from tax to those United Nations officials on the salaries and emoluments paid to them by the United Nations. ... As the ICJ is the principal judicial organ of the United Nations, the Department would recognize any tax exemptions granted to it or its employees and officials pursuant to the Convention on the Privileges and Immunities of the United Nations ("Convention"). ... As pension income from the ICJ is taxable under the Act, the Department must then consider the application of an income tax convention to ensure that Canada's right to tax has not been restricted or denied by the application of that particular convention. ...