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Tax Convention Canada-U.S. Tax Treaty:Art. VII, XII Dear Sirs: This is in reply to your letter of September 1, 1987. ... Income Tax Convention (1980)(the "Canada-U.S. treaty") would be reduced from 25% to 10% by virtue of Article XII of the Canada-U.S. treaty. ...

The employee would not get a deduction in accordance to subparagraph 110(1)(f)(i) of the Act and the Canada-Switzerland Income Tax Convention because the pension payments are not remuneration paid by or on behalf of an employer as required by the exception provided under the second paragraph of article XV of the Income Tax Convention. ...

The Canada-Australia Income Tax Convention also avoids double taxation and it provides the maximum rate of tax which may be imposed by each of the countries on particular sources of income. We are enclosing a copy of Articles 10, 11, 13, 18, and 23 of this Convention which may be helpful to you. ...

Income Tax Convention Art. XVII 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. ... XXX In computing the amount of pension income subject to tax in XXX pursuant to paragraph 212(1)(h) of the Income Tax Act, a deduction of $10,000 was properly allowed by Jonquiere in accordance with Article XVII of the Canada-United Kingdom Income Tax Convention (1978) ("former Article XVII"). ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII 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. ... Pursuant to Article 18 of the Canada-United States income Tax Convention, pensions (other than benefits received under U.S. social security legislation or pensions that would otherwise be exempt from U.S. tax if you remained a resident thereof) arising in the United States and paid to a resident of Canada (i.e. you would be considered a resident of Canada upon immigration) may be taxed in both countries. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII 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, 1980 (the "new treaty"). You have asked that we comment on your conclusion with respect to a number of general categories of payments for television programming set out below. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VII, XIV 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 (1980) for an exemption. We trust that the above comments will be of assistance. ...

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. It is largely a question of fact as to whether or not a permanent establishment exists in any particular circumstances. ... Tax Convention. This would be so whether or not such person performs the actual construction or installation activity itself or engages subcontractors to do so. ...

In his letter to you of September 11, 1987, XXXX gives the following information about a Stichting: XXXXXXXX has asked for your opinion on whether a Stichting should be considered to be a resident of the Netherlands for purposes of the Canada- Netherlands Income Tax Convention, 1986 (the Canada- Netherlands treaty), pursuant to Article 4 thereof, if it is exempt from Dutch tax by virtue of its not carrying on a business or trade. ... Short of the Department of Finance that he has no difficulty in considering a pension plan which is exempt from taxation in the country in which it resides, to be a resident of that country and entitled to the benefit of provisions, in that country's income tax convention with Canada (if any), that are favourable to residents of that country. ...