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Round Table, Q. 25-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A capital gain arising as a result of a distribution of paid-up capital on common shares held by a non-resident generally would be exempt under Article XIII(4) of the Canada-U.S. Convention, unless the gain was derived from shares described in paragraphs 1, 2 or 3. ...

.- Q.1-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Withdrawals from RRSP's are pensions for purposes of Article XVIII of the U.S. Convention. However, the reduced rate of 15% only applies where withdrawals from an RRSP are periodic, i.e., a series of payments for providing retirement income for the greater part of the recipient's life. ...

1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A list of nine criteria for determining whether a Canadian corporation is an independent agent of a U.S. corporation for purposes of Article V(7) of the Canada-U.S. Convention. ...

.- F.Q.16-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 The taxes covered under the Convention do not include provincial taxes, and RC cannot ask for information on behalf of the province. ...

Annual Conference, Q. 12 (January- February 1993 Access Letter, p. 54)-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 Conventions are legally binding in Canada from the time they are enacted. ...

.- Q.82-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 administrative policy re requests for reduced withholding based on Article XVII(2) of the U.S. Convention. ...

23 July 1991 Memorandum (Tax Window, No. 7, p. 15, ¶1368)-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 By virtue of paragraph 1 of Article XIII of the Canada-Barbados Convention, the maximum withholding tax which Barbados may impose on management fees derived from Barbados is 5%. ...

.- Q.55-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 the phrase "borne by an employer in Article XV(2)(b) of the 1980 U.S. Convention means borne by the employer of the particular individual. Where a visiting U.S. employee of the U.S. parent receives direction and control from the management of the Canadian subsidiary, then that subsidiary is his employer. ...

.- Q.38-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 where the IRS alleges that a U.S. subsidiary overpaid its Canadian parent for goods, it is not necessary to refund the alleged overpayment in order to initiate competent authority negotiations (Article XXVI of U.S. Convention). ...

93 C.M.TC- Q. 15-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The reductions in rates of withholding tax pursuant to the 1991 protocol to the Mexico Convention (arising when Mexico agrees to a lower rate in other treaties) do not take effect until the time that the lower rates of withholding tax take effect under the relevant tax treaty between Mexico and the third country, and only apply to the extent that the particular types of payment receive a lower rate of withholding tax under the other tax treaty. ...