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Income Tax Convention and RCAs] K.B. Harding (613) 957-2129 November 10, 1987 Dear Sirs: This is in reply to your letter of September 10, 1987 concerning the application of the Canada- U.S. Income Tax Convention (Convention) to retirement compensation arrangements (RCAs) as proposed in Bill C-64. ... Paragraph 2 of Article XXI of the Convention also provides an exemption from withholding tax on interest and dividends derived by an organization which is "generally exempt from tax in a taxable year" and is "constituted and operated exclusively to administer or provide benefits under one or more funds or plans established to provide pension, retirement or other benefits". ...

Income Tax Convention on CPP and OAS 19(1) B. Fioravanti 613-957-2073 HBW 4125-U3 HBW 4125-U3-1 December 12, 1989 Dear 19(1) In reply to your letter of November 23, we confirm that benefits received under the Canada Pension Plan and the Old Age Security Act are "benefits under the social security legislation" of Canada within the meaning of paragraph 5 of Article XVIII of the Canada-United States Income Tax Convention. ... The Convention provides that one-half of such benefits will be exempt from tax in the United States. ...

Income Tax Convention- Lump Sum Withdrawal from RRSP 5-9445 D. Duff (613) 957-3498 January 25, 1990 Dear Sirs: This is in reply to the letter of April 7, 1989, from 19(1) of your office, and further to our interim letter of August 8, 1989, concerning the application of Article XVII of the Canada-U.K. Tax Convention to lump sum withdrawals from a Registered Retirement Savings Plan (RRSP). ... Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

Income Tax Convention- Interest and Guarantee Fees Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XI, XIII HBW 9412-2-3 24(1) Jim Wilson (613) 957-2063 EACC8742 February 13, 1990 Dear 19(1) RE: 24(1) We are writing in reply to your letter dated January 15, 1990 concerning the tax status in Canada of the above-noted institution. Pursuant to Article XI of the Canada-United States Income Tax Convention, interest and guarantee fees paid by the 24(1) are exempt from Part XIII withholding tax. ...

27 June 1990 Income Tax Severed Letter ACC9359- Canada-Japan Income Tax Convention on Residence Status of Charitable Organization Unedited CRA Tags Canada–Japan Income Tax Convention 2 24(1) David Senécal (613) 957-2074 HBW 4125-J1 Attention: 19(1) June 27, 1990 Dear Sirs: This is further to our letter of March 8, 1990, concerning whether a charitable organization would be considered to be a “resident of a contracting state” for purposes of the residence definition in the tax treaty Canada has with Japan. The Japanese competent authority has concurred with Canada's position that charitable and other exempt organizations are “residents of a contracting state” for purposes of the Canada-Japan Income Tax Convention. ...

5 October 1989 Income Tax Severed Letter 4125- Canada-Austria Income Tax Convention 19(1) David R. ... Pursuant to paragraph 3 of article XXV of the Canada-Austria Income Tax Convention (1976) and in our capacity as Canadian competent authority we wish to confirm our agreement with the following interpretation of Article XIX of the said Convention. ...

4 November 1989 Income Tax Severed Letter AC74463 F- Pensions en provenance de la suisse, Convention fiscale Le 4 novembre 1989 DE- BUREAU PRINCIPAL Section des services bilingues Benoit Mandeville 957-8982 A- DIVISION DES RELATIONS PROVINCIALES ET INTERNATIONALES OBJET: Pensions en provenance de la Suisse Convention fiscale entre le Canada et la Suisse Veuillez trouver ci-joint une demande d'opinion provenant du Service de demande de renseignements aux entreprises (SDRE) qui s'avère être de votre compétence étant donné qu'elle concerne la détermination à savoir si 24(1) est ou non une subdivision politique de la Suisse aux fins de l'application du paragraphe XVIII(2) de la Convention fiscale entre le Canada et la Suisse. ...

Income Tax Convention- Lump Sum Withdrawal from RRSP 5-9277 D. Duff (613) 957-3498 January 25, 1990 Dear Sirs: This is in reply to your letter of December 15, 1989, wherein you requested our interpretation of whether or not a lump sum withdrawal from a Registered Retirement Savings Plan (RRSP) by a United Kingdom resident would be exempt from tax in Canada pursuant to Article XVII of the Canada-U.K. Tax Convention. It is our position that a full or partial lump sum withdrawal from a RRSP would not be considered a pension for purposes of Article XVII(1) of the Canada-U.K. Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article. ...

Income Tax Convention- Whether a Person was Carrying on Business and Had a Permanent Establishment Unedited CRA Tags 31, 253, Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XIII Dear Sirs: Re: Article XIII (9) of the Canada-United States Income Tax Convention, 1980 (the "Convention") This is in reply to your letter dated January 11, 1991 whereby you requested our views concerning whether a farm owned by a resident of the United States would constitute "an asset that on September 30, 1980 formed part of the business property of a permanent establishment situated in [Canada]" within the meaning of subparagraph (c) of paragraph 9 of Article XIII of the Convention. ... Paragraph 1 of Article V of the Convention expressly recognizes that a person may have a permanent establishment in a Contracting State where the business is only partly carried on. ...

CONVENTION- ARTICLE XXIV] January 2, 1984 Interpretations Division Corporate Ruling Section Revenue Canada 875 Heron Road Ottawa, Ontario K1A 0L8 Dear Sirs: CANADA-U.S. CONVENTION- ARTICLE XXIV We request interpretation with respect to Article XXIV of the Canada- U.S. Income Tax Convention which was ratified on August 16, 1984. Under Section 861(b)(2)(B) of the U.S. ...