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Income Tax Convention. The tax liability under Part I.2 is calculated in part by reference to "the individual's income under Part I for the year" (subparagraph 180.2(1)(b)(i) of the Act). ...

It should be noted that the tax treatment described in Situation 2 does not apply to GC Spouses employed as LES at Canadian Embassies in foreign countries where, by virtue of the "Vienna Convention on Diplomatic Relations" (VCDR), the GC Spouses/LES are exempt from income tax otherwise imposed by those countries on the employment income paid by the Canadian Embassies to the GC Spouses/LES. ...

Our views regarding section 255 of the Tax Act, the Income Tax Conventions Interpretation Act and the Mersey Seafoods case remain as stated in the 1998 response. ...

Some of the terms of the obligation may be changed to reflect the different market conventions prevailing for euro-denominated obligations (“reconventioning”). ...

Income Tax Convention. In the event there is a Canadian beneficiary of the trust, generally all distributions made to him from the trust on account of income and not capital will be subject to Part I Tax. ...

C Inc. peut, pour le compte et au nom de V Ltée: a) conclure toutes conventions dans le cours normal de l'entreprise; b) émettre les factures et les autres documents à caractère commercial, et recevoir paiement pour les services rendus dans le cadre de l'exploitation de l'entreprise non réglementée; et c) intenter toute action ou prendre toute voie d'exécution contre des tiers. 9. ...

However, travel to conventions and business meetings in other cities or to other parts of the country would not be personal use. ...

" Under some of Canada's tax treaties respecting the avoidance of double taxation, including the Canada-U.S. 1980 Tax Convention, management fees are covered by the article of the treaty respecting business profits and pursuant thereto business profits of a non-resident enterprise are generally exempt from Canadian tax unless they are attributable to a permanent establishment in Canada through which the non-resident carries on business in Canada. ...

Income Tax Convention (the "treaty") which provides relief from this double taxation. ...

Such Part I or Part XIII Tax would be subject to any relief granted under the Canada- Germany Income Tax Convention. ...