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31 August 1989 Income Tax Severed Letter 5-7778- Disposition of shares by non-resident—Article XIII of the Canada-Israel Income Tax Convention, 1976 Unedited CRA Tags Canada-Israel Income Tax Convention, 1976 Article XIII Dear Sirs: This is in reply to your letter of March 20, 1989 wherein you requested our interpretation of Article XIII of the Canada-Israel Income Tax Convention, 1976 (the “Treaty”). ...

7 August 1990 Income Tax Severed Letter- Leasing transactions and Canada-Singapore Income Tax Convention Unedited CRA Tags 212(13), Article XII of the Canada-Singapore Income Tax Convention Dear Madam: Re: Advance Income Tax Ruling Request This is in reply to your ruling request of July 6, 1990 wherein you requested rulings, among others, that XXX In our telephone conversation of July 12, 1990 we advised you that we will not rule on the proposed leasing transaction described in your ruling request. ... Although we will not rule on how the proposed transaction described in your ruling request would be viewed for purposes of the Income Tax Act (the "Act"), should your client decide to proceed with the proposed transaction you may wish to consider the impact, if any, of subsection 212(13) of the Act and Article XII of the Canada-Singapore Income Tax Convention, 1976. ...

Income Tax Convention- Withholding Taxes on Pension Benefits Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XVIII XXX This is in reply to your letter in which you requested that Canadian withholding taxes on your pension income be reduced or eliminated. ... Income Tax Convention ("Treaty"), the amount of tax that Canada can withhold on pension income paid to a resident of the U.S. is reduced from 25% to 15%. ...

15 March 1990 Income Tax Severed Letter ACC9211- Canada-Austria Income Tax Convention on Pension Income Unedited CRA Tags Canada-Austria Tax Treaty:Art. ... Article XVIII on pension and annuities of the Canada-Austria Convention, exempts certain pensions. These are covered under paragraph 2 which states: "Notwithstanding anything in this Convention, social security pensions, pensions and allowances in respect of military service and any other compensation for an injury or damage sustained as a result of hostilities or past political persecution arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in the first mentioned state". ...

Tax Convention (1978)] XXXX D.S. Delorey (613) 995-2455 November 3, 1982 XXXX Re: Article X Canada-U.K. Tax Convention (1978) This is in reply to your letter of October 18, 1982 concerning the wording in part 5 of the subject Article. ... Convention ...

Income Tax Convention 5-8512 A.B. Adler (613) 957-8962 19(1) September 26, 1989 Dear Sirs: This is in reply to your letter of August 11, 1989 in which you requested our views whether a U.S. trust that is an Individual Retirement Account ("IRA") could be exempt from Canadian withholding tax on Canadian source dividend and interest income by reason of Article XXI, paragraph 2, of the Canada-United States Income Tax Convention, 1980 ("Convention"). ...

1 June 1992 Income Tax Severed Letter 9206526- Canada-Austria Income Tax Convention- Determination of Employer June 1, 1992 Assessment and Accounting Programs Rulings Directorate International Tax Programs Directorate K.B. ... Charette 920652 Canada-Austria Income Tax Convention (the "Convention") Taxability of Employment Income This is in reply to your memorandum of March 2, 1992 wherein you requested our opinion concerning the taxability of an individual in the following hypothetical situation. ... A is a resident of Austria for the purposes of the Convention and is a non-resident of Canada for the purposes of the Act. ...

Income Tax Convention on Oil and Gas Operations International Audits division Specialty Rulings Directorate Olli Laurikainen Attention: David Burton 957-2125 Subject: Article XIII(8) of the Canada-U.S. Income Tax Convention (1980) (the "Convention") This is in response to your memorandum of January 6, 1989 and further to our meeting of May 25, 1989. ... Prescribed treaty provisions such as Article XIII(8) of the Convention clearly give the Minister the right to attach such terms and conditions. ...

Income Tax Convention April 11, 1990 Director General Current Amendments and Specialty Rulings Directorate Regulations Division D.W. ... Convention Your memorandum (prepared by R.C. O'Byrne) dated March 14, 1989 was sent to Finance for their comments. ...

30 January 1990 Income Tax Severed Letter ACC89766- Canada-Australia Income Tax Convention 19(1) c-8976 Al Watson (613) 957-2072 Attention: January 30, Dear Sir: We have received the attached material that was requested from the Western Regional Office, Operations. The attached material is being provided pursuant to Article 25 of the Convention between Canada and Australia. ...