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Tax Convention Canada-U.S. Tax Treaty:Art. VI, XII, XXX Q1. What is the tax rate for resource royalties under the new treaty? ...

Tax Convention 1980 to the type of transactions described above. This memo also points out that, generally, for Canadian resident shareholders who are not citizens of the U.S. there is no potential for double taxation and that there may be relief from double taxation of Canadian resident shareholders who are U.S. citizens if they apply to the U.S. tax authorities for such relief. ...

Income Tax Convention (1980). With respect to your reference to subsection 212(11) of the Act, it has been our longstanding position that where the payment is out of a trust governed by a pension plan, the particular provisions of paragraph 212(1)(h) of the Act override the general provisions of subsection 212(11) of the Act. ...

Income Tax Convention (1980). However, there is a provision of the Income Tax Act which allows you to elect to file a tax return as though you were a resident of Canada. ...

Income Tax Convention (1980) would exempt such payment from tax in Canada, except to the extent that the management fee was attributable to a permanent establishment in Canada of-A. ...

Question 7 It is very difficult to answer this question because we do not have specific rules other than that it must be for the purpose of administering a tax covered by the convention. ...

It was announced by the Department at the 1981 Canadian Tax Foundation Convention (Revenue Canada Round Table, Q. 12, “Treaty Shopping”- copy attached) that as a result of certain facts having come to the Department's attention it would no longer issue advance rulings on these arrangements. ...

Article XVIII of the Canada-Switzerland Income Tax Convention would apply to reduce the tax on the pension benefits from 25% to 15% of the benefit. ...

Le taux d'impôt est de 25% du montant brut des intérêts payés, à moins que ce taux soit réduit conformément aux dispositions d'une convention fiscale bilatérale. ...

Income Tax Convention (1980) unless the shares are described in subparagraph 3(b)(ii) thereof. ...