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Income Tax Convention (1980). Hence, the Canadian payor is obligated, pursuant to subsection 215(1) of the Income Tax Act, to withhold the applicable 10% rate of tax and remit same to the Receiver General by the 15th day of the month following the month in which the tax was withheld. ...

Income Tax Convention (1980), the rate of Canadian Part XIII tax on interest paid to a resident of the U.S. is 15%. ...

Income Tax Convention. We trust that you will find our comments helpful. ...

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. ...

Income Tax Convention (1980) (the "Treaty"). In our view, any computer software payment that can reasonably be considered to be on or in respect of a copyright in respect of the production or reproduction of the software does qualify for an exemption from Canadian withholding tax under subparagraph 212(1)(d)(vi) of the Act and under Article XII of the Treaty.  ...

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. ...

Therefore, if the United States resident has a permanent establishment in Canada, he could be subject to tax on that income pursuant to section 14 of the Act and Article VII of the Canada-United States Income Tax Convention (1980). ...

Income Tax Convention concerns exempt organizations that receive dividend and interest income. ...

I refer to your letter of March 21, 1984 concerning the non-discrimination Article of the Canada-United Kingdom Double Taxation Convention. ...

15 August 1986 Income Tax Severed Letter August 15th, 1986 Director Reorganizations & Non-Resident Division Specialty Rulings Directorate Legislative & Intergovernmental Affairs Branch Revenue Canada, Taxation Head Office Ottawa, Ontario K1A 0L8 Dear Sir, CANADA- BRAZIL INCOME TAX CONVENTION (THE "TREATY") Could you please confirm whether the following three assumptions are correct with respect to the above-captioned Treaty. 1. ...