Search - convention

You describe the facts as follows: XXX You have concluded that the payments in question, given that they are taxable pursuant to paragraph 6(1)(f) of the Act, are also taxable under Article XV of the Canada-Philippines Income Tax Convention (the Convention). ... In regard to the Convention, it is our opinion that the exemption from Canadian taxation provided therein pursuant to paragraph 2 of Article XV thereof does not apply. ... In addition, paragraph 2 of Article XV of the Convention does not apply to exempt the disability payments to the non-resident individual from taxation in Canada. ...

31 May 1984 Income Tax Severed Letter 5-6250-]Article IV of the Canada-United Kingdom Income Tax Convention] C. ... Tax Convention, the Treaty contains no specific reference to place of incorporation. ... Canada) relating to the taxes which are the subject of the Convention. ...

26 July 1988 Income Tax Severed Letter 5-5492 F- [Entente d'échelonnement du traitement et convention de retraite] M. Shea-DesRosiers (613) 957-8953 Le 26 juillet 1988 Messieurs, Objet: Entente d'échelonnement du traitement et convention de retraite La présente fait suite à votre lettre du 22 Janvier 1988 concernant le sujet ci-haut mentionné. ... " Par conséquent, un tel régime ne peut constituer une "convention de retraite" même si l'employé peut retarder la réception des sommes investies dans le régime jusqu'à la date de cessation de ses services ou de sa retrsite, puisqu'une entente d'échelonnement du traitement est expressément exclue de la définition de "convention de retraite" au paragraphe 248(1) de la Loi. ...

Income Tax Convention- Employee's Salary Reimbursed by Registered Charity 901575 R.S. ... Tax Convention (1980) (the Convention). You described the hypothetical fact situation as follows: 1. ... As such the remuneration would be borne by an employer resident in Canada for purposes of paragraph 2(b) of Article XV of the Convention and the exemption therein would not extend to the employee in question. ...

Income Tax Convention Article XIII, Paragraph 9] T.B. Kuss (613) 957-2117 Attention: XXXX October 8, 1992 Dear Sirs: Re: Canada- U.S. ... Income Tax Convention (the "U.S. Convention") to the following hypothetical situation. 1. ... Convention (the "Paragraph") should provide relief in respect of the capital gains, however the extent of that relief is unclear. ...

Income Tax Convention (1980) (the Convention). You describe the facts as follows: I. ... For purposes of the Convention, specifically paragraph 2 of Article IV thereof, Mr. ... However, pursuant to paragraph 2(a) of Article XVIII of the Convention, the aggregate Part I tax payable by Mr. ...

30 March 1993 Income Tax Severed Letter 9303490- Young Presidents Organization Convention Expenses Unedited CRA Tags 9 18(1)(a) 18(1)(b) 18(1)(h) 67 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. ... RESPONSE #5 It is always a question of fact to be determined in each case as to whether a training or convention expense is on account of capital or income, whether it is personal, or whether it is reasonable in the circumstances. ... The Department's current general positions on training expenses and convention expenses are stated in Interpretation Bulletins IT-357R2 dated November 6, 1989 and IT-131R2 dated November 24, 1989, respectively. ...

7 August 1990 Income Tax Severed Letter- Calculation of gains exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XIII Dear Sirs: Re: Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your letter dated May 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

18 April 1990 Income Tax Severed Letter ACC9185- Canada-China Income Tax Convention on Interest on Deposits Earned in Canada 19(1) Jim Wilson (613) 957-2063 HBW 4125-C2 HBW 6591-C2 April 18, 1990 Dear 19(1) Re: 24(1) Article XI of the Canada-China Income Tax Convention We are writing in regard to your letter dated January 17, 1989 (copy attached), in which you requested confirmation on the tax status of the 24(1) regarding interest earned on deposits held in Canada. Our Vancouver District Office replied to the letter on April 4, 1989 (copy attached) and acknowledged tax exemption to the 24(1) in accordance with paragraph 3, Article 11 of the Canada-China Income Tax Convention. ... Article 3 of Convention delegates the competent authority function to your Ministry of Finance ar its authorized representative. ...

Income Tax Convention, 1980] Revenue Canada Taxation Head Office Attention: XXXX T.B. ... Income Tax Convention, 1980 This is in reply to your letter of July 29 regarding the above-referenced subject. ... Income Tax Convention, 1980 (the "Convention") would apply in a situation where a Canadian resident individual elects under subsection 85(1) of the Act on the transfer of his interest in a U.S. partnership to his wholly-owned Canadian corporation. ...