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Le Ministère s'en remet donc aux dispositions de la convention conclue entre le locataire et le locateur. ...

Tax Convention applies to pensions and annuities paid from the U.S. to residents of Canada. ...

Income Tax Convention provides that the Contracting State where the taxpayer is resident will provide a foreign tax credit in order to avoid double taxation. ...

Income Tax Convention (1980). Assuming that the subsequent sale was not part of the series of transactions that included the dividend and that the buyer would never have offered to purchase the shares of Subco I or the underlying business and assets now owned and operated by Subco II, you question whether we would view the subsequent sale as having resulted from the series of transactions. ...

Neither section 255 of the Act nor section 5 of the Income Tax Conventions Interpretation Act defining the meaning of the word "Canada" are relevant to. the operation of a fishing vessel. ...

It is granted that under some of Canada's tax treaties including the Canada-Germany Income Tax Convention (1981), remuneration earned by a Canadian notional from governmental service would be taxable only in Canada. ...

Article 13 of the Canada-Germany Income Tax Convention will override our domestic laws (as described in 1 through 4) where the non-resident disposes of taxable Canadian property that is neither immovable property nor shares forming part of a substantial interest in the capital stock of a company of which is a resident of Canada the value of which shares is derived principally from immovable property situated in Canada. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII, Reg. 105 Dear Sirs: This is in reply to your letters of November 21 and November 29, 1985. ...

Where annuity payments are received out of an RRSP by a person resident in Australia, the 25% Part XIII tax is reduced to 15% by virtue of Article 18 of the Canada-Australia Income Tax Convention Act, 1980. 3. ...

Income Tax Convention or by an estimate of his income and expenses, the withholding otherwise required by section 105 of the Regulations may be waived. ...