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Income Tax Convention (the "Treaty"). As a result they may be subject to a withholding tax of 25% by virtue of paragraph 212(1)(d) of the Act and Article 22 of the Treaty unless, of course, they are considered business profits t-o the non-resident and the non-resident does not have a permanent establishment in Canada. ...

In addition, neither section 255 of the Act, which expands the definition of "Canada" for purposes of mineral, oil, and gas activities, nor section 5 of the Income Tax Conventions Interpretation Act defining the meaning of the word "Canada", are relevant to the operation of a vessel. ...

Question 7 It is very difficult to answer this question because we do not have specific rules other than that it must be for the purpose of administering a tax covered by the convention. ...

17 February 1977 Income Tax Severed Letter F PAR AVION Le 17 février, 1977 Cher XXXX La présente fait suite à votre lettre du 21 décembre 1976, ayant trait à votre demande de renseignements concernant la convention réciproque Canada-Belgique. ...

Tax Convention, this tax is exigible only on that amount by which the superannuation payments exceed $10,000 or £5,000, whichever is the greater. ...

Income Tax Convention (the "Treaty"). Generally speaking, when an individual was taxed by both Canada and the U.S. on the same income, alleviating provisions contained in the law of either country would ensure that there was no double taxation. ...

Harding XXXX Re: Canada-Italy Income Tax Convention- Article 13 This is in reply to your letter of January 19, 1984, wherein you requested our opinion with respect to several questions outlined therein in the following hypothetical situation. ...

Harding Dear XXXX Re: Canada-Italy Income Tax Convention- Article 13 This is in reply to your letter of January 19, 1984, wherein you requested our opinion with respect to several questions outlined therein in the following hypothetical situation. ...

Tax Convention Article 27A, paragraph 4- Service Vessels (A) Confirmation of Ownership of the Vessel including: (i) Date of Purchase confirmed by a copy of the sale agreement. ...

Under the current Canada-United Kingdom Income Tax Convention (1978), the exemption provided under the 1966 Agreement was not carried forward. ...