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Tax Convention Canada-U.S. Tax Treaty:Art. XII Dear Sirs: This is in reply to your letter of June 30, 1986 requesting information concerning Canadian withholding taxes as they apply to computer software marketed in Canada by a U.S. based software company. ... Tax Convention (1980). We are enclosing a copy of Information Circular 76-12R3 for your purposes. ...

Income Tax Convention Art. III Dear XXX We are writing In regards to your letter of August 2, 1989, concerning the tax treatment of pensions upon immigration to Canada. Pursuant to Article III of the Canada-United Kingdom Income Tax Convention, pensions received from Britain while a resident of Canada will be taxable only in Canada. ...

It also applies to payments made to employees or members of the association to assist them in covering their expenses to attend various conventions and meetings as delegates on behalf of the association, provided attendance at such conventions and meetings is to further the aims and objectives of the association. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII, XIII, XXI Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Income Tax Convention (the "treaty") Facts: On November 20, 1991 Doreen Guy (Ottawa D.0.) requested a technical interpretation regarding the above treaty articles. ...

Income Tax Convention, because a U.S. withholding tax has already been levied on the remittances referred to in 2 above. ... Income Tax Convention, it is our view that nothing contained therein prevents Canada from imposing a Part XIII tax on applicable payments made to a U.S. resident. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XV Dear Sirs: Re: Subsections 156(1) and 153(2) of the Income Tax Act (Canada) (the “Act”) We are writing in response to your letter dated February 26, 1990 in which you requested our opinion on the application of subsections 156(1) and 153(2) of the Act to the following hypothetical situation. ... Income Tax Convention (1980) (the “Treaty), be exempt from taxation in Canada. ...

In connection with your reference to the OECD Model Convention, in our view amounts paid or credited by the trusts in question would conform to "Article 21: Other income" in the OECD Model Convention; "Article 6: Income from immovable property: would be applicable where the non-resident receives the income directly. ...

Income Tax Convention Art. XXI Dear Sirs: This is in reply to your letter of May 24, 1985 wherein you requested our opinion on the application of certain provisions of the Canada-United Kingdom Income Tax Convention (1976)("the Treaty"). ...

In connection with your reference to the OECD Model Convention, in our view amounts paid or credited by the trusts in question would conform to "Article 21: Other income" in the OECD Model Convention; "Article 6: Income from immovable property: would be applicable where the non-resident receives the income directly. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII, 56(1)(a)(i)(C.1), 56(1)(x), 56(1)(z), 60(1)(j), 110(1)(f)(i) Dear Madam: This is in reply to your letter of April 19, 1991 concerning proposed legislation relating to foreign retirement arrangements. ... Income Tax Convention (1980) will apply with the result that the Canadian resident will be entitled to a deduction under subparagraph 110(1)(f)(i) of the Income Tax Act (the "Act"). ...