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Income Tax Convention (1980) (the "Convention") This is in response to your memorandum of January 6, 1989 and further to our meeting of May 25, 1989. ... In addition, in the case of U.S. corporations, the claims made against the $500,000 cumulative Part XIV tax exemption referred to in Article X(6) of the Convention by the disappearing corporations would continue to affect the total claim available to the surviving corporation. ... Prescribed treaty provisions such as Article XIII(8) of the Convention clearly give the Minister the right to attach such terms and conditions. ...

27 February 1990 Ministerial Correspondence 57484 F- Canada-Australia Income Tax Convention on Residence Unedited CRA Tags n/a 19(1) File No. 5-7484   R.C. O'Byrne   (613) 957-2126 February 27, 1990 Dear Sirs: Re:  Article 4 Canada-Australia Income Tax Convention (the "Convention") This is in reply to your letter of January 30, 1989 in which you asked whether an Australian Non-Profit Society (a "Society") would be considered a resident of Australia for purposes of the Convention.  ... Accordingly, we are of the view that Article 4(2) of the Convention would not preclude a Society from being considered resident in Australia for purposes of the Convention. ...

Income Tax Convention Unedited CRA Tags Canada/U.s. Treaty, Art. 15 Dear Sirs: Re:  Article XV(2)(b) of the Canada-United States Income Tax Convention. 1980 (the "Convention")  This is in reply to your letter dated December 6, 1990. Your proposed representation of the Department's position concerning the application of the above-noted provision of the Convention where a United States parent company ("U.S.Co. ... In our opinion, whether or not a resident of Canada is an "employer" for purposes of subparagraph 2(b) of Article XV of the Convention is essentially a question of fact.  ...

Income Tax Convention- Deemed Residence Unedited CRA Tags Treaty US Article IV, 250(1)(a) Dear Sirs: Re:  Canada- U.S. ... You have asked whether the tie-breaker rules in Article IV of the Convention would apply to this individual. ... Paragraph 1 of Article IV of the Convention does not mention citizenship as a basis for liability to tax.  ...

Income Tax Convention on Taxation of Estates Unedited CRA Tags n/a 19(1) File No. 5-9194   G. ... Income Tax Convention, 1980 U.S. Estate Taxes This is in reply to your letter dated December 4, 1989. ... The US competent authority pursuant to Article XXVI of the Canada-United States Income Tax Convention, 1980 is:      Mr. ...

26 June 1990 Ministerial Correspondence 5901004 F- Pension and Annuity Payments under Canada-Trinidad and Tobago Income Tax Convention Unedited CRA Tags n/a 24(1) File No. 5-901004   D.S. Delorey   (613) 957-3495 Attention: 19(1) June 26, 1990 Dear Sirs: Re: Article XIII  Canada-Trinidad and Tobago Income Tax Agreement (the "Trinidad Convention") This is in reply to your letter of May 28, 1990 concerning the meaning to be given to the terms "pension" and "annuity" for the purposes of Article XIII of the Trinidad Convention. ... For the purposes of interpreting reciprocal tax conventions, we generally take the view that the term "pension" refers to a payment that is to be made periodically for the life of (or the greater part of the life of; e.g., to age 90) the recipient, unless a definition in a particular treaty dictates otherwise. ...

Income Tax Convention on Canadian Tax and Filing Obligations Unedited CRA Tags 69(3), 150(1), 150(2), 115 24(1) 900414   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9245 August 30, 1990 Dear Sirs: Re:  Canadian Tax and Filing Obligations U.S.- Canada Tax Convention This is in reply to your letter dated March 20, 1990 to the Non-Resident Taxation Division.  ... In particular we note that the Commentary on the Model Double Taxation Convention on Income and Capital in the Report of the OECD Committee on Fiscal Affairs, 1977 is consistent with the view that USCo has a permanent establishment in Canada. ...

16 January 1990 Ministerial Correspondence HAA4093N14 F- Canada-Netherlands Income Tax Convention- Pension of Public Employees Unedited CRA Tags n/a   January 16, 1990 Mr. ... Wilson   957-2063   HAA 4093-N1-4   HBW 6591-N1      HBW 4125-N1 19(1) Canada-Netherlands Tax Convention Article 18 We are writing in reply to your memorandum dated July 27, 1989, concerning the above-noted taxpayer. ...

14 August 2007 Ministerial Correspondence 2007-0239511M4- Convention Expenses Unedited CRA Tags 20(10) Principal Issues: What are the criteria for the deductibility of convention expenses? ... It is not necessary that the taxpayer be a member of the organization sponsoring the convention, but attendance at the convention must be related to the business or professional practice carried on by the taxpayer. ... Tax Convention, its territorial scope is considered to include the United States for purposes of deducting convention expenses. ...

Your question Does Article XIII of the Convention exempt the total capital gain from taxation in Canada? Our views The definition of taxes covered in subparagraph 2(a) of Article II of the Convention indicates that in the case of Canada the existing taxes to which the Convention shall apply include those levied under Part I of the Act.  As minimum tax is levied under Part I of the Act it is covered by the Convention. ...