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Under a tax convention or agreement, which is similar to the OECD Model, Canada will apply the provision of the "Business Profits" article where the Canadian company carries on business in the other Contracting State through a permanent establishment. ...

Investment income paid by a Canadian source and received by a non-resident would normally be subject to withholding tax of 25% under Part XIII of the Act unless reduced by tax conventions. ...

The impact of the "tiebreaker" rule should also be pointed out under the heading "Calculation of Taxable Income". 3) The example outlined in paragraph 3 on page 2 could be expanded to deal with the dual residency problem and the impact of the Canada-France Income Tax Convention on such a situation. ...

Excessive Portion of "Management Fees" Although it may be argued that the benefit conferred on USCo is a management fee, albeit an excessive one, and is therefore taxable under paragraph 212(1)(a) of the Act, it is our view that, since other sections of the Act are more clearly applicable and since the application of paragraph 212(1)(a) of the Act may trigger arguments by the taxpayer that the benefits are business profits to USCo and are treaty exempt (by virtue of Article VII of the Canada-US Income Tax Convention (1980)), this would not be the most worthwhile avenue to pursue. ...

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. ...

La question de déterminer si le transfert par un particulier d'actions d'une société à une fiducie dont il est le bénéficiaire constitue une disposition pour les fins du sous-alinéa 55(3.1)b)(i) de la Loi est une question de fait qui ne peut être déterminée sans un examen de la convention de fiducie, ni sans connaître quel droit (jurisdiction) régit la fiducie. ...

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

Ignoring the Canada- France Income Tax Convention, the taxpayer would be subject to Canadian tax on his world income including any remuneration from the O.E.C.D. ...

Income Tax Convention ("US Treaty") as set out in the July 21, 1989 letter prepared by Keith Harding. ...

This is not only reasonable, it is within the spirit of the law and the Income Tax Conventions which Canada has with various countries. ...