Search - convention

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

Income Tax Convention requires a different treatment that article would prevail over domestic law. ...

Tax Convention, regular annuities for life in accordance with a matured RRSP or periodic payments made under a RRIF would be exempt from withholding tax in Canada. ...

À notre avis, même si les études sont poursuivies dans le cadre du régime de perfectionnement prévu à l'article 14 de la convention des professeurs, les frais de scolarité remboursés par l'employeur pour de telles études sont imposables. ...

It is not on account of any specific duties he may perform, such as attending a convention or travelling on municipal business for which he is usually reimbursed. ...

Tax Convention (1980) (the "Treaty"). Accordingly, it is your view that 24(1) should withhold 15% of the gross payments to the taxpayer. ...

The rate of such tax payable by residents of the United States may be reduced to 105 by virtue of Article XII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

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 (1980). (d) If the funds transferred from the U.S. pension plan are subjected to a U.S. withholding tax, a foreign tax credit would be allowed with respect to such withholding. 3. ...