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Income Tax Convention Unedited CRA Tags none Dear Sir: This is in regard to your request that we provide you with a determination of the residency of the late XXX We have reviewed the documents which you submitted and are of the view that XXX had established significant residential ties with Canada and would therefore be considered a factual resident of Canada for the calendar years XXX on June 24, 1985. ... Income Tax Convention (1978) would determine his residency for income tax treaty purposes. ...

22 October 1986 Income Tax Severed Letter 5-2278- [Canada-Brazil Income Tax Convention (the "Treaty")] M. Trotier (613) 957-8968 October 22, 1986 Dear Sir: Re: Canada-Brazil Income Tax Convention (the "Treaty") As you requested during the Canadian Bankers' Association meeting on October 1, 1986, this is to clarity our position concerning two tax sparing issues under Article 22 of the Treaty. ...

7 October 1990 Income Tax Severed Letter- Determination of Residence under Canada-Germany Income Tax Convention Unedited CRA Tags Canada-Germany Income Tax Convention Dear Sirs: Re: Request for Technical Interpretation We are writing in response to your letter, dated July 31, 1990 regarding a German citizen who has personal and economic ties with both Canada and Germany. ...

13 February 1990 Income Tax Severed Letter SCC8749- Canada-Korea Income Tax Convention 19(1) HBW 4125-K3 Jim Wilson (613) 957-2063 February 13, 1990 Dear 19(1) RE: 24(1) We are writing in reply to your letter dated January 11, 1990, concerning the Canada- Korea Income Tax Convention and the status of the above-noted financial institution. ...

Income Tax Convention and Partnerships 5-9341 O. Laurikainen (613) 957-2129 24(1) 19(1) Dear Sirs: Re: Canada-U.S. Income Tax Convention (1980) (the "Treaty") and Partnerships This is in response to your letter dated December 22, 1989 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

13 April 1987 Income Tax Severed Letter 5-3050- [Canada-UK Income Tax Convention] XXXX G. ... Income Tax Convention (the "Treaty") This is in reply to your letter of March 9, 1987 setting out your view that in a series of withdrawals from an RRSP which are paid to a resident of the U.K., only the final payment would be subject to withholding taxes pursuant to paragraph 212(1)(l) of the Income Tax Act (the Act) and Article 17 of the Treaty. ...

Income Tax Convention (the "Treaty")] XXXX G. Thornley (613) 957-2130 December 17, 1986 Dear Sirs: Re: Canada-U.K. Income Tax Convention (the "Treaty") This is in reply to your letter of November 10, 1986 requesting a technical interpretation of Article XXVII(2) of the Treaty in the following hypothetical situation. 1. ...

Tax Conventions] G. Thornley (613) 957-2130 November 18, 1986 Dear Sir: Re: Canada-U.S. Tax Conventions This is in reply to your letter of August 25, 1966 concerning the taxation of world wide income of Canadians who are deemed residents of the United States. ...

Income Tax Convention (1980) (the "Treaty") and Partnerships] Revenue Canada Taxation Head Office XXX J. ... Income Tax Convention (1980) (the "Treaty") and Partnerships This is in response to your letter dated November 6, 1991 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

22 January 1990 Income Tax Severed Letter ACC8916- Canada-Finland Income Tax Convention- Social Security Pensions from Finland 19(1) HBW 4125-F1 Jim Wilson (613) 957-2063 January 22, 1990 Dear 19(1) We are writing in regards to the tax treatment of Finnish social security pensions paid to residents of Canada. We have recently received enquiries as to whether social security pensions from Finland meet the definition of "pension" or "annuity" under Article II of the Canada-Finland Income Tax Convention (1958). ...