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30 December 1986 Income Tax Severed Letter

Castendyk 957-2063 Dear Sir: We are writing to you in connection with Articles 25, 22 and 11 of the Canada-Brazil Income Tax Convention. ...

12 May 1987 Income Tax Severed Letter

It should be borne in mind, however, that the Canada- Brazil Income Tax Convention has only recently gone into force and we should probably not expect any information in respect of taxable years beginning before 1986. ...

10 February 1986 Income Tax Severed Letter

Sider: We are writing with respect to our conversations in early December, 1985 concerning the application of Article XXVIIA of the Canada-United Kingdom Income Tax Convention (the "Treaty"). ...

13 February 1985 Income Tax Severed Letter

XXXX The form NR7-R cannot be processed as payments out of a Registered Retirement Savings Plan are subject to a flat rate of 25% non-resident tax at source in accordance with the revised Canada- United Kingdom Tax Convention. ...

26 February 1985 Income Tax Severed Letter F

Notre comprehension des faits est la suivante: Une clause de la convention collective d'une institution d'enseignement Prevoit qu'un professeur peut renoncer a la renumeration a laquelle il aurait droit par ailleurs pour assumer une tache administrative ou une charge de cours d'appoint. ...

8 March 1984 Income Tax Severed Letter

Guglich (613) 995-1723 Attention: XXXX March 8, 1984 Dear Sirs: This is in reply to your letter of May 17, concerning Article 13(4)(a) of the Canada-United Kingdom Income Tax Convention wherein you requested our view as to whether gross or net asset values will be used in determining whether shares derive the greater part of their value from immovable property. ...

12 August 1985 Income Tax Severed Letter A-1659 - [U.S. Tax Reform Act - Deemed Residents of the U.S.]

Income Tax Convention (1980)- and, in this particular case, under the greater relief provisions of Article XXX of the new treaty, to the exemption under Article VIII of the former treaty. ...

7 May 1975 Income Tax Severed Letter

Our own advice to the clients presently transferring people abroad (permanently), is to enact a Reciprocal Agreement between the affiliates, and provide pension for all service in the 'assuming' Employers plan reducing the resulting pension by any pension being paid from the 'ceding' employers Plan (Tax conventions usually apply when pensions are payable). ...

17 December 1984 Income Tax Severed Letter

In addition, the Canada-United Kingdom Tax Convention does not provide for a specific exemption from withholding tax in Canada with respect to United Kingdom pension funds investing in Canada or vice versa. ...

30 April 1980 Income Tax Severed Letter

Convention Art. 16 s. 16 ...

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