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Miscellaneous severed letter

13 October 1992 Income Tax Severed Letter 9227335 F - Congé trait. diff.

Selon la convention collective de travail des fonctionnaires 1989-1991, les employés peuvent utiliser leurs jours de congé de maladie non utilisés et accumulés aux fins d'une Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information préretraite. Durant cette période de préretraite, les personnes affectées sont considérées comme des employés couverts par la convention collective. ...
Miscellaneous severed letter

27 November 1989 Income Tax Severed Letter 7-4504B

Income Tax Convention Art. XVII, Canada–U.S. Tax Convention Canada-U.S. ...
Miscellaneous severed letter

16 July 1985 Income Tax Severed Letter A-1559

Tax Convention Canada-U.S. Tax Treaty:Art. XII Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... If it does so, you ask us to confirm your view that pursuant to the provisions of parts 2, 6 and 8 of Article XI of the Canada-United States Income Tax Convention 1980 (the "Treaty"), there will be no Part XIII tax exigible under the Act in respect of interest paid by the Partnership to persons who are not residents of Canada. ...
Miscellaneous severed letter

7 October 1988 Income Tax Severed Letter 95-1025 F

Income Tax Convention (the "Convention"). 2. A lump sum payment from a deferred profit sharing plan ("DPSP"). ...
Miscellaneous severed letter

1 August 1988 Income Tax Severed Letter

In the case of a U.K. subsidiary of the Bank that has funds on deposit with a U.K. branch of the Bank, the applicable treaty is the Canada-United Kingdom Income Tax Convention (1978). Article VII of the Convention is entitled "Business Profits" and paragraph 1 thereof provides that the profits of an enterprise of a Contracting State (in this case, the U.K.) shall be taxable only in that state (i.e., the U.K.) unless the enterprise carries on business in the other Contract- ing State (i.e., in Canada) through a permanent establishment situated therein. ...
Miscellaneous severed letter

8 November 1985 Income Tax Severed Letter A-1982 - [Retiring Allowance Paid to U.S. Resident]

Income Tax Convention (1980) (the "new treaty"), Article XXXXII thereof permits the full operation of paragraph 212(1)(j.1) including the rate specified therein. 3) As provided in Article XXXX(2)(b) thereof, the new treaty has effect with respect to a payment of a retiring allowance made in a taxable year beginning on or after January 1, 1985. ... Income Tax Convention (1942) (the "old treaty") will continue to have effect for the first taxable year covered by Article XXXX(2)(b). 4) Article XI of the old treaty would in fact have afforded such greater relief to elements (a), (b) and (d) of the settlement payment because such elements are not "earned income" as referred to in that Article and thus the Part XIII tax rate would have been limited to 152. ...
Miscellaneous severed letter

20 December 1982 Income Tax Severed Letter

Tax Treaty states that "in the event of any inconsistency between the provisions of this part, or the convention, and the provisions of any other law, the provisions of this part and the convention prevail to the extent of the inconsistency". ...
Miscellaneous severed letter

17 November 1987 Income Tax Severed Letter

Paragraph 4 of Article XXXXIV of the Convention does not preclude Canada from applying subsection 20(11) of the Income Tax Act and therefore the non-business income tax, as defined in paragraph 126(7)(c), is automatically reduced by the amount deducted under subsection 20(11) of the Act. ... Since this is in accordance with the provisions of Article XVIII and XXIV of the Convention, the U.S. will treat a portion of the pension income as arising in Canada in order to avoid double taxation as provided for in paragraph 6 of the latter Article. ...
Miscellaneous severed letter

28 October 1986 Income Tax Severed Letter 5-1999 - [861028]

However, in determining the residency status of an Australian resident temporarily visiting Canada, the provisions of Article 4 of the Canada-Australia Income Tax Convention must be considered. ... Your Canadian earnings as an exchange teacher will be subject to tax, unless the provisions of Article 15 of the Canada-Australia Income Tax Convention dictate otherwise. ...
Miscellaneous severed letter

5 December 1985 Income Tax Severed Letter 5-0090 - [851205]

Income Tax Convention (1980), remuneration received by a person resident in the U.S. is taxable only in Canada if it is paid by the government of Canada to a Canadian citizen in respect of services rendered in the discharge of functions of a governmental nature. (b) Pursuant to the Canada-Belgium Tax Convention (1975), remuneration received by a person resident in Belgium is taxable only in Canada if it is paid by the government of Canada in respect of services rendered to the government of Canada, unless the individual is a national of Belgium or became a resident of Belgium other than solely for the purpose of performing the services. ...

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