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Kuss (613) 957-2120 November 12, 1986 Dear Sirs: Re: Canada-Brazil Income Tax Convention (the "Treaty") We would like to clarify our position stated in our letter dated February 27, 1986 which was in response to your letter of December 19, 1986. ...

INCOME TAX CONVENTION On October 15, 1981 you were good enough to advise us of the Department's assessing position with respect to dividends received from U.K. corporations in light of Article XXVII(4) of the above treaty. ...

Article XXI(5) of the new Canada-United States Income Tax Convention sets out the conditions under which such deductions may be allowed for purposes of United States taxation. ...

If on filing the return for the year, it is concluded that under the Act or the Convention the tax withheld is in excess of that required, the surplus will then be refunded. ...

Parce que vous auriez choisi l'option de 4 ans offert en vertu de la convention collective avec votre employeur, vous recevriez un traitement réduit, équivalent à 87,5% de votre traitement habituel pendant les 4 années de l'option, incluant les six mois de congé. ...

Income Tax Convention reduces the withholding rate to 10 per cent where the use payments are made to a resident of the United States. ...

Income Tax Convention. Canadian residents could be deemed to have à gain. 21(1)(a) We understand that amendments to the Act to deny such gains and losses are currently being considered. ...

The rate of withholding tax applicable to the "dividend" would be subject to the Canada-U.S. tax convention in effect at the time the dividend is deemed to be paid. ...

Income Tax Convention permits Canada to tax such royalty payments made to U.S. residents, however, the rate of withholding tax on such payments is limited to 10% of the gross amount of the royalty payments. 21(1)(b) for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

We further agree with XXXX that the above answer applies to non-resident crew members from both the Faroe Islands (not a treaty country) and Denmark (a treaty country), and that in the latter case the meaning of the term "Canada" contained in section 5 of the Income Tax Conventions Interpretation Act as well as the provisions of paragraph 3 of Article XIII of the Canada-Denmark treaty are irrelevant to this question. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...