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13 February 1990 Income Tax Severed Letter ACC8745 - Privileges and Immunities of International Organizations

More specifically, article II, section 7 of the Convention on the Privileges and Immunities of the United Nations provides that the 24(1) assets, income and property will be exempt from all direct tax in Canada. ...

13 August 1986 Income Tax Severed Letter 5-1586 - []

Tax Convention Canada-U.S. Tax Treaty:Art. XII XXX Re: Subsection 212(5) of the Income Tax Act (the "Act") This is in reply to your letter of May 5, 1986 asking for our confirmation that television programming transmitted by cable constitutes television for purpose of subsection 212(5) of the Act. ...

2 May 1980 Income Tax Severed Letter RCT-0550

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC In response to your memorandum of April 14, 1980, we suggest that you proceed with a formal request to obtain the IRS's opinion on computer software payments. ...

31 May 1990 Income Tax Severed Letter RRRR411 - Tax treatment of certain pensions received from Canada and paid to U.S. residents

Thus, pursuant to paragraph xxxxx Article 18 of the Canada-United States Income Tax Convention, it is not taxable in the United States. ...

16 March 1982 Income Tax Severed Letter RRRR58 - Non-resident withholding tax on interest exemption

It would appear that the XXX may be exempt from Canadian income tax pursuant to Article X the Canada-United States Tax Convention. ...

7 July 1991 Income Tax Severed Letter - Foreign tax credits

Income Tax Convention. The transactions described in your letter appear to reflect a factual situation and in our view should be handled as an advance income tax ruling request. ...

7 February 1991 Income Tax Severed Letter - Contributions to foreign social insurance and pension plans non-deductible

Income Tax Convention (1978) provides no such relief. In the event the above information does not satisfy your requirements, we would be prepared to review a more specific enquiry detailing the residency status of the employee, complete information concerning the plan involved, etc. ...

7 March 1991 Income Tax Severed Letter - Exemption from Withholding Tax

Under the “Privileges and Immunities (International Organizations) Act of Canada” in correlation with Article 11, Section 7 of the “Convention on the Privileges and Immunities of the United Nations”, the Governor in Council made an order dated April 29, 1982 (SOR/82-464) under which ESA has the privileges set forth in Article 11, Section 7, paragraph (a), i.e. the ESA, its assets, income and other property are exempt from all direct taxes, thus being exempt from Canadian income tax on all income. ...

22 December 1982 Income Tax Severed Letter 72214

Bilateral treaties and Income Tax Conventions normally exempt shipping profits?? ...

3 June 1988 Income Tax Severed Letter 95-5923 F

Income Tax Convention. It is our view that benefits paid from the CPP would fall within the social security legislation of Canada, however, you may wish to confirm this interpretation with the Internal Revenue Service. ...

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