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17 August 1988 Income Tax Severed Letter 5-5698 F- [Convention de Retraite] F. ... Aux fins de la partie I et XI.3 de la Loi de l'impôt sur le revenu (la "Loi"), cet arrangement constitue-t-il une convention de retraite? ... Selon nous, ce montant ne provient pas d'une convention de retraite tel que mentionné au dit alinéa. ...

7 March 1991 Income Tax Severed Letter- Canada-Switzerland Income Tax Convention Unedited CRA Tags 212, Canada-Switzerland Income Tax Convention Dear Sirs: Re: Canada-Switzerland Income Tax Convention (1976) (the "Convention") This is in reply to your letter dated December 17, 1990 whereby you request our opinion concerning the taxation of amounts paid by an estate of an individual who at the time of death was resident in Canada to XXX You have not provided sufficient information to permit us to express a conclusive opinion in respect of the matter raised by your letter. ... Paragraph 7 of Article X of the Convention will likely also apply in respect of amounts paid by an estate resident in Canada to a beneficiary resident in Switzerland. If paragraph 7 of Article X of the Convention is applicable the rate of Canadian income tax exigible under paragraph 212(1)(c) of the Act will be reduced from 25% to 15%, irrespective of the source of the estate's income (i.e. paragraph 7 of Article X does not only apply in respect of distributions made by an estate related to dividends received by the estate). ...

Convention Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 13 923320 24(1) G. ... Income Tax Convention This letter is in reply to your fax dated November 5, 1992 in which you requested our views with respect to paragraph 7(b) of Article XIII of the Canada-U.K. ... Convention. 4. Office buildings (if not rental property or inventory) and the land under and/or adjacent thereto and necessary for the use thereof are Excluded Property. 5. ...

Income Tax Convention on Taxation of Estates 19(1) 5-9194 G. Arsenault (613) 957-2126 Dear Sir: Re: Article XXV of the Canada-U.S. 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. ...

Income Tax Convention (1980) (the "Convention") limits Canada's tight to tax a U.S. company to those situations where the company carries on business in Canada through a permanent establishment. Article V of the Convention defines a "permanent establishment" as a fixed place of business in Canada through which the business of a resident of the United States is wholly or partly carried on. ... We are enclosing a copy of the Convention and a T2 Corporation Income tax Guide for your perusal. ...

Income Tax Convention- Retirement Compensation Arrangement 19(1) 5-9190 D.S. ... Income Tax Convention (the "U.S. Convention") Retirement Compensation Arrangement ("RCA") This is in reply to your letter of November 30, 1989 requesting our views on the interpretation to be given to the terms "retirement plan" and "periodic pension payment" contained in Article XVIII of the U.S. ... Convention. It is our view that the rate of tax on the amounts paid to a U.S. resident in a situation such as that described above would be 25%. ...

Income Tax Convention Unedited CRA Tags 54(g), 250, 85, 116, 40(2)(b), Canada–U.S. ... Income Tax Convention (1980) (the Convention). You describe the facts as follows: 1. ... For purposes of the Convention, specifically paragraph 2 of Article IV thereof, Mr. ...

Income Tax Convention Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 5 Dear Sirs: Re: Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter dated September 14, 1990 whereby you asked the following questions concerning paragraph 3 of Article 5 of the Convention: 1. ... Paragraph 3 of Article 5 of the Convention must be interpreted by giving meaning to the words used therein. ... In our opinion, the phrase "shall not be deemed to include" in the introduction of paragraph 3 of Article 5 of the Convention is synonymous with "shall be deemed not to include". ...

7 October 1991 Income Tax Severed Letter- Meaning of \"International Traffic\" in Canada- Netherlands Income Tax Convention Unedited CRA Tags Canada- Netherlands Income Tax Convention Subject: Meaning of "International Traffic" in Canada- Netherlands Income Tax Convention, 1986 The term "international traffic" is defined by paragraph 1(g) of Article 3 and Paragraph II of the Protocol to the Convention. ... " In connection with the interpretation/definition of the term "international traffic" in the Canada-Netherlands Convention reference must also be made to Paragraph II of the Protocol. ... " Thus the definition of the term "international traffic" in the Canada-Netherlands Convention is in effect virtually the same as the definition in the Canada-United States Income Tax Convention, 1980. ...

Income Tax Convention on Employment Income 24(1) 5-9792 M.P. Sarazin (613) 957-2125 Dear Sirs: Re: Clause 115(2)(e)(i)(B) of the Income Tax Act (Canada) (the "Act") and the Canada-U.K. Tax Convention (the "Convention") This is in reply to your letter dated March 6, 1990 in which you requested our advice regarding the reporting requirements in the following situation. ... Facts 24(1) Your client has based his calculation of withholding tax upon the interaction of clause 115(2)(e)(i)(B) of the Act and paragraph of Article 15 of the Convention. ...