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Income Tax Convention (the "treaty") (see our comments below re "international traffic"), such profits would be taxable in Canada by virtue of Article VII of the treaty only to the extent that they are attributable to a permanent establishment in Canada through which the U.S. airline carries on business in Canada. ... For the purposes of this Convention, the term 'permanent establishment' means a fixed place of business through which the business of a resident of a Contracting State is wholly or partly carried on. ... For the purposes of the Convention, the provisions of this Article shall be applied in determining whether any person has a permanent establishment in any State. ...

Income Tax Convention (1980) (the "Convention") provides a transitional relief provision regarding certain capital assets described therein. ... In interpreting and applying Article XIII, paragraph 9 of the Convention, will Revenue Canada afford Canadian resource property held by U.S. persons the fresh start transitional relief rules contained in Article XIII, paragraph 9 of the Convention? ... Income Tax Convention, i.e. as a result of the U.S. resident not having a permanent establishment in Canada, provided that such properties are not excluded by virtue of paragraphs 9(c), (d) and (e) of Article XIII of the Convention. ...

Opco is a XXXXXXXXXX with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention, and is an indirect wholly owned subsidiary of Pubco. ... The central control and management of FA1 is and will be in XXXXXXXXXX, and FA1 is and will be resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. The central control and management of FA2 is and will be in XXXXXXXXXX, and FA2 is and will be resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. ...

You can scroll through the board or go directly to a topic by sub-searching on a keyword (eg DOCP) in the following index: DOCA 95/7/3 Indians- RRSP'S & Investment Income DOCB 95/7/3 Tax Convention- Resident of a Contracting State DOCC 95/6/30 Incestuous share purchases DOCD 95/6/28 Payments to foster homes DOCE 95/6/28 Medical expenses Directorate Information DOCM Mandate DOCN Mailing Address & General Phone Numbers DOCP Work Section Phone Numbers DOCA Indians- RRSP's & Investment Income Principal Issues: Taxation of status Indians with respect to RRSP withdrawals and investment income. ... DOCB TAX CONVENTION- RESIDENT OF A CONTRACTING STATE XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX DOCC Incestuous Share Purchases XXXXXXXXXX XXXXXXXXXX DOCD PAYMENTS TO FOSTER HOMES Principal Issues: emergency home fees: are they exempt under para 81(1)(h)? ...

You can scroll through the board or go directly to a topic by sub-searching on a keyword (eg DOCP) in the following index: DOCF 95/8/31 PART I.3 TAX- DEFERRED REVENUE DOCB 95/7/3 Tax Convention- Resident of a Contracting State DOCC 95/6/30 Incestuous share purchases DOCD 95/6/28 Payments to foster homes DOCE 95/6/28 Medical expenses Directorate Information DOCM Mandate DOCN Mailing Address & General Phone Numbers DOCP Work Section Phone Numbers DOC F PART I.3 TAX- DEFERRED REVENUE July 20, 1995 MEMORANDUM TO FILE Financial Institutions Section 951794 PART 1.3- TAX ON LARGE CORPORATIONS & DEFERRED REVENUE- NON FINANCIAL INSTITUTIONS The following sets out the Department's position for purposes of Part 1.3 tax with respect to deferred revenue recorded on the balance sheet of a corporation. ... DOCB TAX CONVENTION- RESIDENT OF A CONTRACTING STATE XXXXXXXXXX XXXXXXXXXX DOCC Incestuous Share Purchases XXXXXXXXXX XXXXXXXXXX DOCD PAYMENTS TO FOSTER HOMES Principal Issues: emergency home fees: are they exempt under para 81(1)(h)? ...

Where the Governor-in-Council, by order, has allowed an international organization to have the privileges and immunities set forth in Article II of the Convention on the Privileges andImmunities of the United Nations, section 7 thereof exempts its assets, income and other property from all direct taxes in Canada.  ...

We are also of the opinion that an amount received by a Canadian resident as a distribution from a U.S. qualified pension plan and rolled over into an IRA is pension income that would be excluded from taxable income in Canada within the meaning of paragraph 1 of Article XVIII of the Income Tax Convention. ...

The Canada-United Kingdom Tax Convention provides that there is no withholding of tax in the U.K. on the first $10,000 (5,000) of pension income. ...

De plus, le contribuable est autorisé, dans le calcul de son revenu imposable, à déduire, en vertu du sous-alinéa 110(1)f)(i) de la Loi et du paragraphe 5 de l'article XVIII de la Convention fiscale de 1980 entre le Canada et les États-Unis, la moitié du montant de prestations de sécurité sociale des États-Unis inclus dans son revenu. ...

Income Tax Convention, such payments made to the U.S. resident will be subject to a 10% withholding tax. ...