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Income Tax Convention amounts of alimony paid by a resident of the U.K. to a Canadian resident would be taxable only in Canada. ...

Therefore there is no capital gain or capital loss, until a disposition of property has taken place, after your client has taken up Canadian residence. c) The annuity payments received by your client after he has taken up residence in Canada are exempt from tax from the United Kingdom, as provided by Article XVI of the Canada-United Kingdom Tax Convention but are taxable in Canada from the date your client has become a resident of Canada. ...

Article VI(1)(b) of the Canada-United States Tax Convention exempts the individual taxpayer from tax in the United States. 3. ...

Tax Convention (1978) (the "treaty"). In the first place, if the fee is considered to be part of the business profits of the U.K. company, it should not be subject to withholding tax pursuant to Article VII of the treaty unless the U.K. company has a permanent establishment in Canada. ...

Hiltz Director RE Canada-Brazil Income Tax Convention ("the Treaty") Article 22, paragraphs 2 and 3 We have recently dealt with a technical interpretation of the above-referenced Treaty provisions. ...

Tax Convention I am writing to seek your opinion on a matter of interpretation. ...

We also enclose copies of our Information Bulletin "L1 on the subject of visiting teachers and a comparative listing of the professor and teacher articles from the fourteen agreements or conventions with other nations in which there are such articles. ...

Article XVII of the Canada-United Kingdom Tax Convention (1978) states that pensions arising in Canada and paid to a resident of the United Kingdom may be taxed in the country of residence. ...

(b) Subject to the exceptions provided in proposed subsection 67.1(2) and the provisions relating to conference and convention fees in proposed subsection 67.1(3), it is the Department's view that proposed subsection 67.1(1) will apply where an amount "in respect of the human consumption of food or beverages or the enjoyment of entertainment" is included as part of a larger bill for services rendered or as part of a bona fide non-arm's length management or administration fee charged by a non-resident. ...

Income Tax Convention, and that the exemption therein was not restricted by Article XXVII(2) of the Treaty. ...