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9 March 1983 Income Tax Severed Letter 5-4858 - Meaning of “permanent establishment” for purposes of paragraph 3(f) of the Protocol to the present Canada-U.S. Tax Convention

Tax Convention Unedited CRA Tags Canada-U.S. Tax Convention Protocol paragraph 3(f) Dear Sirs: This is further to our letter of January 27, 1983 in reply to your enquiry of December 2, 1982 and your recent conversation with Mr. ... Tax Convention. It is largely a question of fact as to whether or not a permanent establishment exists in any particular circumstances. ... Tax Convention. This would be so whether or not such person performs the actual construction or installation activity itself or engages subcontractors to do so. ...

19 September 1984 Income Tax Severed Letter A-0464 - [Canada—U.S. Tax Convention]

Tax Convention] Mr. Butler, Director Non-Corporate Rulings Division Revenue Canada- Taxation 875 Heron Road Ottawa, Ontario K1A OL8 Re: Canada- U.S. Tax Convention Dear Sir: I would appreciate receiving your opinion on the following matter: Entry Into Force Under Article XXX, the Convention shall enter into force on October 1, 1984 for tax withheld at source on dividends, interest, royalties, pensions and annuities. ... Treasury dated April 26, 1984 "accurately reflects understandings reached in the course of negotiations with respect to the interpretation and application of the various provisions in the 1980 Tax Convention as amended. ...

30 August 1990 Income Tax Severed Letter ACC9245 - Canada-U.S. Income Tax Convention on Canadian Tax and Filing Obligations

Income Tax Convention on Canadian Tax and Filing Obligations 900414 C. Arsenault (613) 957-2126 24(1) Attention: 19(1) August 30, 1990 Dear Sirs: Re: Canadian Tax and Filing Obligations U.S.- Canada Tax Convention This is in reply to your letter dated March 20, 1990 to the Non-Resident Taxation Division. ... In particular we note that the Commentary on the Model Double Taxation Convention on Income and Capital in the Report of the OECD Committee on Fiscal Affairs, 1977 is consistent with the view that USCo has a permanent establishment in Canada. ...

31 May 1990 Income Tax Severed Letter ACC9105 - Canada-Japan Income Tax Convention

31 May 1990 Income Tax Severed Letter ACC9105- Canada-Japan Income Tax Convention 19(1) HBW 4125-J1 David Senécal (613) 957-2074 Attention May 31, 1990 Dear 19(1) We are writing further to our letter of March 6, 1990 and 19(1) recent telephone enquiry to our office concerning the application of the Canada-Japan Income Tax Convention to charitable and other non-profit organizations. ...

Income Tax Severed Letter AC59107R F - Convention du 17 décembre 1984

Income Tax Severed Letter AC59107R F- Convention du 17 décembre 1984 5-9107 A. Lebeau (613) 957-4363 Le 22 janvier 1990 Maitre, Objet: 24(1) 19(1) Convention du 17 décembre 1984 La présente fait suite à vos lettres du 6 et 16 novembre 1989 requérant le bureau principal de reconsidérer sa position du 8 septembre 1989 relativement au sujet mentionné ci-dessus. ...

31 May 1990 Income Tax Severed Letter ACC9106 - Canada-U.S. Income Tax Convention - Treatment of Certain Pensions

Income Tax Convention- Treatment of Certain Pensions 19(1) HBW 4125-U3-1 (Article 18) Jim Wilson (613) 957-2063 May 31, 1990 Dear 19(1) We are writing in reply to your letter dated May 10, 1990, concerning the tax treatment of certain pensions received from Canada. ... Thus, pursuant to paragraph Article 18 of the Canada-United States Income Tax Convention, it is not taxable in the United States. ...

26 March 1990 Income Tax Severed Letter ACC9205 - Canada-Italy Income Tax Convention on Pensions

26 March 1990 Income Tax Severed Letter ACC9205- Canada-Italy Income Tax Convention on Pensions Unedited CRA Tags 3 19(1) David R. Senécal (613) 957-2074 HBWW 4125-17 EACC9205 March 26, 1990 Pursuant to your request of March 10, 1990, please find enclosed certain documentation dealing with the recent amendments to the Canada-Italy Tax Convention as they pertain to the tax treatment of pensions paid by the Italian government to residents of Canada. ...

31 May 1990 Income Tax Severed Letter RRRR410 - Application of the Canada-Japan Income Tax Convention to charitable and other non-profit organizations

31 May 1990 Income Tax Severed Letter RRRR410- Application of the Canada-Japan Income Tax Convention to charitable and other non-profit organizations Unedited CRA Tags none David Senécal (613) 957-2074 Attention: May 31, 1990 Dear: xxxxx We are writing further to our letter of March 6, 1990 and xxxxx recent telephone enquiry to our office concerning the xxxxx of the Canada-Japan Income Tax Convention to charitable and other non-profit organizations. ...

5 February 1990 Income Tax Severed Letter ACC8730 - Competent Authority Request under Canada-Finland Tax Convention

5 February 1990 Income Tax Severed Letter ACC8730- Competent Authority Request under Canada-Finland Tax Convention Unedited CRA Tags none TELEX MESSAGE EACC8730 Originator: B. FIORAVANTI Date: 5/02/90 Branch: LEGISLATION Building: MACDONALD Room Number: 1000 Telephone Number: 957-2073 Other Destination: FINLAND 123241 FIMIN SF Attention: 19(1) Message: RE: 19(1) COMPETENT AUTHORITY REQUEST UNDER CANADA- FINLAND TAX CONVENTION OUR INTERNATIONAL AUDITS DIVISION HAS WRITTEN TO YOU ON APRIL 14, 1988, AND FURTHER ON NOVEMBER 2, 1988, AND JUNE 1, 1989. ...

23 July 1990 Income Tax Severed Letter EACC9492 F - Canada-Korea Income Tax Convention

23 July 1990 Income Tax Severed Letter EACC9492 F- Canada-Korea Income Tax Convention Unedited CRA Tags n/a 19(1) HBW 4125-K3 David R. ... In our capacity as the Canadian competent authority for the purposes of the Canada-Korea Income Tax Convention, we have informed the Korean authorities of our view 24(1) We will communicate with you further, once we have received a reply from the Korean authorities. ...

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