Search - convention

16 January 1990 Income Tax Severed Letter ACC8919- Canada-Netherlands Income Tax Convention- Pension of Public Employees January 16, 1990 Provincial and International Relations Division J. ... Solley Manager, Public Affairs Penticton District Office 19(1) Canada-Netherlands Tax Convention Article 18 We are writing in reply to your memorandum dated July 27, 1989, concerning the above-noted taxpayer. ...

1 March 1990 Income Tax Severed Letter ACC9218- Canada-USSR Income Tax Convention Unedited CRA Tags Canada-U.S.S.R. ...

7 December 1990 Income Tax Severed Letter- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags Canada–Germany Income Tax Agreement Dear Sir: Re: Article 13 of the Canada-Germany Income Tax Agreement (1981) (the “Agreement”) We are writing in reply to your letter dated October 18, 1990 wherein you brought to our attention the fact that the assumption made in our letter dated August 14, 1990 that the West-German “Gesellschaft des buergerlichen Rechts” (“GbR”) is a private corporation is not correct. ...

Income Tax Convention Unedited CRA Tags 20(11), 20(12), 126 Dear Sirs: This is in answer to your letter of September 6, 1990 concerning section 126 of the Income Tax Act (the Act) with respect to a Canadian resident individual who owns shares of a U.S. corporation which corporation elects to be taxed as a subchapter S corporation. ...

As the words “salary or wages” are not defined in Canada’s Conventions, these words have the same meaning for the purposes of the Dependent Personal Services Article of the Conventions as they do under the Act by virtue of the General Definitions Article in the Conventions or section 3 of the Income Tax Conventions Interpretation Act (the “ITCIA”). ... Income Tax Convention (the “U.S. Convention”) The Dependent Personal Services Article of the U.S. ... Convention which applied to income not otherwise dealt with in that Convention. ...

As the words “salary or wages” are not defined in Canada’s Conventions, these words have the same meaning for the purposes of the Dependent Personal Services Article of the Conventions as they do under the Act by virtue of the General Definitions Article in the Conventions or section 3 of the Income Tax Conventions Interpretation Act (the “ITCIA”). ... Income Tax Convention (the “U.S. Convention”) The Dependent Personal Services Article of the U.S. ... Convention which applied to income not otherwise dealt with in that Convention. ...

Income Tax Convention (the "Convention"). It is our view that where an income tax convention or agreement uses the word "gains" it is referring to capitol gains otherwise the term income, business profits or some other specific type of income is generally referred to. When interpreting a passage of a tax agreement or convention which is not clear, the Income Tax Conventions Interpretations Act (the "Interpretations Act") permits the interpreters to review the background papers and the intention of the negotiators when drafting the tax agreement or convention. ... As an example, amounts that constitute income from real property which fall within the specific provisions of Article VI of the Convention could not fall within Article XIII of the Convention as the income from real property provision is more specific. ...

Tax Convention Canada-U.S. Tax Treaty:Art. IV, XXIX This is in reply to your letter of April 10, 1989 in which you asked us two questions about dual residency under the Convention. ... As a result there is no relief under the Convention from taxation in Canada. In our opinion paragraph 2 of Article XXIX ("Article XXIX(2)") of the Convention would not affect a residency determination under Article IV(3) of the Convention. ...

Convention in particular. Position: Please see memorandum attached. Reasons: RESIDENCY UNDER CANADA'S INCOME TAX CONVENTIONS The determination of the residency of a taxpayer for the purposes of one of Canada's income tax conventions is the foundation on which the balance of the provisions of the particular convention are applied. ... Income Tax Convention (1980) (the "Convention"), but in addition set down broad guidelines for the interpretation of income tax conventions in general. ... Protocol Article 3 of the new protocol to the Convention introduces several changes to the Residence Article of the Convention. ...

Muirhead: We are writing to request your interpretation of the impact of the Canada-United States Income Tax Convention, 1980 on the deductibility of convention expenses incurred by a taxpayer resident in Canada in attending a convention held in the United States. ... For example, it is our view that if an association of Nova Scotia general insurance agents were to hold a business meeting or convention in Florida, expenses incurred by member companies in sending employees to the convention should be deductible under Subsection 20(10). However, if the same Nova Scotian association were to hold a convention in Ontario, without any affiliation or joint activities with an Ontario or national organization of insurance agents, members attending the convention would not be entitled to deduct expenses incurred to attend the convention because Ontario is outside the territorial scope of the Nova Scotia association. ...