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Income Tax Convention, 1980 (the "Convention")] Revenue Canada Taxation Head Office XXXX T.B. ... Income Tax Convention, 1980 (the "Convention") This is in response to your letter dated October 24, 1988 in which you requested a technical interpretation of the above- referenced provisions of the Convention. ...

Income Tax Convention, 1980 (the "Convention")] T.B. Kuss (613) 957-2120 July 22, 1987 Dear Sirs: Re: Articles IV and XXI of the Canada-U.S. Income Tax Convention, 1980 (the "Convention") This is in reply to your letter of July 2, 1987 regarding the above- referenced subject. ...

25 March 1991 Income Tax Severed Letter 910104- [Article XIII(9) of the Canada-United States Income Tax Convention, 1980 (the "Convention")] Revenue Canada Taxation Head Office G. Arsenault (613) 957-2126 Attention XXXX Mar 25 1991 Dear Sirs: Re: Article XIII(9) of the Canada-United States Income Tax Convention, 1980 (the "Convention") This is in reply to your letter dated January 11, 1991 whereby you requested our views concerning whether a farm owned by a resident of the United States would constitute "an asset that on September 30, 1980 formed part of the business property of a permanent establishment situated in [Canada]" within the meaning of subparagraph (c) of paragraph 9 of Article XIII of the Convention. ... Paragraph 1 of Article V of the Convention expressly recognizes that a person may have a permanent establishment in a Contracting State where the business is only partly carried on. ...

Income Tax Convention (1980) (the “new treaty”) vs. Canada-U.S. Income Tax Convention (1942) (the “old treaty”) Unedited CRA Tags none This is in response to your memorandum of June 9, 1989. ...

Income Tax Convention- Exemption Unedited CRA Tags n/a   February 13, 1990 To: Montreal District Office From:  Head Office Financial Industries Division Attention: Mr. ... Income Tax Convention ("Convention") Enclosed, for your information and use, are copies of our recent correspondence with 19(1) of the legal firm of 24(1) in Montreal, concerning 19(1) claim for an exemption from Canadian income tax under the Convention. ...

12 December 1991 Income Tax Severed Letter 913289A F- Canada – Switzerland Income Tax Convention Unedited CRA Tags Treaty Switzerland Article 5, Paragraph 3 Canada – Switzerland Tax Convention Article V, Paragraph 3            This is in reply to your memos dated November 28 and December 3, 1991 regarding the above matter.  ... Paragraph 3 of Article XV of the Canada – Switzerland Tax Convention (the "Convention") states that, notwithstanding the preceding provisions of that Article (Dependent Personal Services), remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by an enterprise of a Contracting State, shall be taxable only in that State. ... It would be easier to make a case that the above result was not intended if the language of the subject Article was peculiar to the Convention, however this is not the case.  ...

16 January 1990 Income Tax Severed Letter HBW4125B F- Canada-Brazil Income Tax Convention- Interest Income Unedited CRA Tags n/a 19(1) HBW 4125-B   B. Fioravanti   (613) 957-2073 January 16, 1990 Dear 19(1) Re:  Canada-Brazil Income Tax Convention Tax-Sparing Provisions Further to your letters of June 3, 1988 and March 25, 1987, we have re-examines our position and are still of the view that paragraph 3 of Article 22 of the Canada-Brazil Income Tax Convention does not apply to interest income arising from a loan booked through a permanent establishment in a third state.  ... By deeming Brazilian tax to have been paid at a rate of 20 percent, and by limiting the rate of tax actually imposed on a company, the Canada-Brazil Income Tax Convention deliberately creates a discrepancy between the two figures.  ...

12 October 1989 Income Tax Severed Letter ACC8587 F- Canada-France Tax Convention Unedited CRA Tags n/a   October 12, 1989 S. ... Pettifer 957-2072      HBW 4125-F1 24(1) PARAGRAPH 5, ARTICLE XXIX CANADA-FRANCE INCOME TAX CONVENTION As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada. ...

7 June 1991 Income Tax Severed Letter- Canada-Korea Income Tax Convention Unedited CRA Tags Canada-Korea Income Tax Convention (1978) Articles 4, 18 and 22 Dear Sirs: Re: XXX Canada-Korea Income Tax Convention (1978) (the "Convention") This is in reply to your letter to International Audit Division dated May 2, 1991 which, as you know, was referred by that Division to us. ... However, you have not suggested that Korea has acted not in accordance with the Convention. ... Assuming the payments to XXX are not royalties covered by Article 12 of the Convention, we assume (based on the very limited information that you provided) that the taxation of the payments by Korea would be governed by Article 7 of the Convention. ...

Income Tax Convention (the "Convention"). It is our view that where an income tax convention or agreement uses the word "gains" it is referring to a capital gains otherwise the term income, business profits or some other specific type of income is generally referred to. When interpreting a passage of a tax agreement or convention which is not clear, the Income Tax Conventions Interpretations Act (the "Interpretations Act") permits the interpreters to review the background papers and the intention of the negotiators when drafting the tax agreement or convention. ... As an example, amounts that constitute income from real property which fall within the specific provisions of Article VI of the Convention could not fall within Article XIII of the Convention as the income from real property provision is more specific. ...