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Miscellaneous severed letter

19 October 1992 Income Tax Severed Letter 9210095 - Loans to Non-residents

Income Tax Convention the rate of withholding tax in the above circumstances shall not exceed 10% of the gross amount of the dividend. ...
Miscellaneous severed letter

11 January 1992 Income Tax Severed Letter 922480A - Swiss Organization - Whether Non-profit

Where exemption from Canadian tax is claimed under the Canada- Switzerland Income Tax Convention we would require an indication of the specific provision(s) you view as relevant, in order that we might express an opinion. ...
Miscellaneous severed letter

22 September 1992 Income Tax Severed Letter 9224897 F - Echange d'actions

Si dans une situation donnée, un contribuable dispose en 1988 d'actions d'une corporation canadienne qu'il a acquises au terme d'une convention visée au paragraphe 7(1.1) de la Loi et reçoit en contrepartie de la disposition ou de l'échange de l'argent et des actions, le paragraphe 7(1.5) de la Loi ne s'appliquera pas parce qu'il a reçu une contrepartie autre que des actions. ...
Miscellaneous severed letter

9 January 1992 Income Tax Severed Letter 9128145 - Earned Income — U.S. Resident for Treaty Purposes Only

S. for the purposes of the Canada-United States Income Tax Convention, 1980 (the "U. ...
Miscellaneous severed letter

8 September 1987 Income Tax Severed Letter 5-3792

Tax Convention provides that income received from an estate or trust resident in Canada by a resident of the United Kingdom who is a beneficial owner shall not exceed 15% of the gross amount of the payment. ...
Miscellaneous severed letter

29 October 1986 Income Tax Severed Letter 7-0898

Consequently, such payments made from the trust to XXX should be subject to 25 per cent withholding since the Canada-Switzerland Income Tax Convention does not provide for a reduced rate of withholding tax on interest from a trust. ...
Miscellaneous severed letter

10 March 1987 Income Tax Severed Letter 5-3149A

Income Tax Convention withholding tax on periodic payments out of a retirement plan is reduced to 15%. ...
Miscellaneous severed letter

20 June 1988 Income Tax Severed Letter 7-2751

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

18 October 1982 Income Tax Severed Letter 97-2090 F

Income Tax Convention, a bonus consideration payment will be considered to be an exempt gain on disposition of a capital asset. ...
Miscellaneous severed letter

7 May 1986 Income Tax Severed Letter 95-3149 F

Income Tax Convention withholding tax on periodic payments out of a retirement plan is reduced to 15%. ...

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