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Income Tax Convention (1980) (the "Treaty", and, Partnerships] Revenue Canada Taxation Head Office O. ... 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. ...

7 November 1987 Income Tax Severed Letter RRRR120- Information Circular 76-12R3 Footnote (6) Canada-Norway Income Tax Convention Unedited CRA Tags 212(1)(d) As discussed with you in a recent telephone conversation, we suggest that you consider amending Information Circular 76-12R3 to clarify the Department's position on the rate of withholding tax that applies to rental income from moveable property received by a resident of Norway from a resident of Canada. ...

Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. ...

Income Tax Convention] MEMORANDUM March 10, 1983 TO Provincial and International Relations Division Mr. ... Income Tax Convention (1978) (the "Treaty") We enclose the letter dated December 20, 1982 from XXXX concerning the above-mentioned Treaty and its application to a repurchase of shares by a U.K. corporation from an individual shareholder who is resident in Canada or from a corporate shareholder which is resident in Canada and owns less than 10% of the voting power of the U.K. corporation. ...

19 December 1986 Income Tax Severed Letter 5-2426- [Canada-Switzerland Income Tax Convention] XXXX G. Thornley (613) 957-2130 December 19, 1986 Canada-Switzerland Income Tax Convention (the "Treaty") This is in reply to your letter of October 29, 986 requesting a technical interpretation of the provisions of Article XIII of the above noted treaty in a hypothetical fact situation. ...

Income Tax Convention on Pensions Jim Wilson (613) 957-2063 HBW 4000-3 April 30, 1990 Dear 19(1) We are writing in regards to your letter dated April 14, 1990, concerning the tax treatment of certain pensions upon immigration to Canada. Pursuant to Article 18 of the Canada-United States Income Tax Convention, pensions (other than benefits received under U.S. social security legislation or pensions that would otherwise be exempt form U.S. tax if you remained a resident thereof) arising in the United States and paid to a resident of Canada (i.e. you would be considered a resident of Canada upon immigration) may be taxed in both countries. ...

Income Tax Convention Re Withholding Tax on Pensions Unedited CRA Tags none Dear XXX We are writing in follow-up to your telephone conversation on November 23, 1990, with Mr. ...

Income Tax Convention on Pension 19(1) 901544 G. Arsenault (613) 957-2126 19(1) This is in reply to your letter dated July 9, 1990 whereby you enquired concerning a pension paid to you by 24(1) We do not have sufficient information to permit us to express a definitive opinion. ...

10 April 1990 Income Tax Severed Letter ACC9191- Canada-Ireland Income Tax Convention Jim Wilson 19(1) 613-957-2063 HBW 4125-I2 HBW 6591-I2 EACC 9191 April 10, 1990 Dear 19(1) Re: 19(1) We are writing in reply to your letter dated March 5, 1990, concerning the interpretation of the Canada-Ireland Income Tax Agreement (the "Agreement"). ...

Income Tax Convention (1980) Unedited CRA Tags 20(1)(v.1), Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. VI, XIII This memorandum is in response to yours of June 27, 1989 in which you requested our opinion concerning the characterization of property as real property situated in Canada which, upon alienation by a resident of the United States, can result in a taxable gain in Canada pursuant to Article XIII of the Treaty. ...