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Consequently, the 40 percent payment would not be deductible by Company B and Company A would be subject to 25% withholding tax unless relief if provide under a tax agreement or convention. ...

D'autre part, nous sommes d'avis qu'une police d'assurance-vie ne constitue normalement pas un élément d'actif utilisé dans une entreprise exploitée activement par une corporation lorsqu'une telle police d'assurance-vie est détenue dans le but de distribuer un dividende aux actionnaires ou de financer une convention entre actionnaires relative à l'achat d'actions au décès d'un actionnaire. ...

Income Tax Convention, where the individual is liable for tax in the U.S. by reason of his residence or domicile, the U.S. will have exclusive right to tax remuneration received during that period where the services are performed in the U.S.. ...

The Canadian income tax liability of a resident of the United States may be reduced or eliminated by the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

28 May 1990 Income Tax Severed Letter RRRR245- Canadian tax treatment of the German corporation tax credit Unedited CRA Tags 20(11), Canada-Germany Income Tax Convention Articles 7 and 10 Your file Votre référence Our file Notre référence 5-8474 O. ...

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. ...

Generally, subject to paragraph 81(1)(a) of the Act, (a) where a non-resident corporation that does not have a permanent establishment in Canada pays tax on rent from real property situated in Canada pursuant to section 216 of the Act, the rent that is taxable under section 216 in a year is included in calculating the corporation's taxable income earned in the year in determining the corporate surtax under section 123.2 payable in respect of the return filed under section 216; and (b) taxable capital gains realized in the year by a non-resident corporation that does not have a permanent establishment in Canada from the disposition of taxable Canadian property are included in calculating the corporation's taxable income earned in the year in determining the corporate surtax under section 123.2 payable in respect of income of the kind referred to in subsection 115(1) of the Act By virtue of paragraph 81(1)(a) of the Act, amounts that are exempt from income tax by virtue of a tax convention or agreement between Canada and another country that has the force of law in Canada are not to be included in computing the income of a corporation. ...

7 February 1991 Income Tax Severed Letter- Canada-Germany Income Tax Agreement- Interest in Partnership Unedited CRA Tags Canada-Germany Income Tax Convention, Art. 13(4), (5) Dear Sirs: Re: Articles 13(4) and (5) of the Canada-Germany Income Tax Agreement (1981) (the “Treaty”) This is in reply to your letter dated March 31, 1989. ...

This latter deduction is one which is allowed for certain amounts of income exempted from taxation in Canada under a foreign tax convention such as exists between Canada and the U.S.A. ...

Tax Convention. 4. In Year 4 Canco agrees to waive its right to repayment of the loan. ...