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Income Tax Convention (1980) (the "Convention"). The exception in (2) is due to the fact that the software development work is performed in the U.S. ... We also agree that the payments described in (3) and (4) are royalties and thus are subject to a reduced withholding rate of 10% under Article XII(2) of the Convention. ... Thus the fee described in (5) in our view is subject to withholding at 10% under Article XII(2) of the Convention. ...

Income Tax Convention, 1980 We have been asked to review the Commentary to the Canada- U. ... Under Article XVIII(3) of the Convention, however, the term pensions includes a pension or retirement plan. ... Another rule of interpretation relevant to question 1) is found in Article 111(2) of the Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XV December 14, 1992 International Tax Programs Rulings Directorate Directorate K.B. ... Income Tax Convention (the "Convention") and since they are dealt with in that Article they are not subject to Article XXII of the Convention. ... Since the Convention does not define salary or wages, paragraph 2 of Article III of the Convention provides that any term not defined in the Convention shall, unless the context otherwise requires, have the meaning it has under the Act. ...

Article 19(1)(a) of the Canada-Italy Income Tax Convention (1977) (the "Convention") provides that remuneration, other than a pension, paid by a Contracting State to an individual in respect of services rendered to that State shall be taxable only in that State. ... Thus, in our view the taxpayer meets the prerequisite in Article 9(1) of being a resident of Italy for purposes of the convention. ... As provided for in subsection 8(3) of the Canada-Italy Income Tax Convention Act, 1980, in the event of any inconsistency between the provisions of the Convention and the provisions of any other law, the provisions of the Convention prevail to the extent of the inconsistency. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XXIV:5(a) File No 921358 24(1) 957-2125 D. ... Tax Convention Paragraph 5(a) of Article XXIV of the Convention This is in reply to your letter of April 23, 1992 wherein you requested our interpretation of how Article XXIV, paragraph 5(a) applies to determine the extent to which Canada and the United States may tax a certain type of royalty income. ... In essence your inquiry raises the question of whether the flow through rules with respect to income emanating from U.S. resident trusts, under paragraph 2 of Article XXII of the Convention will apply for the purposes of Article XXIV of the Convention concerning the elimination of Double Taxation. ...

Income Tax Convention (the "Convention") issued by the U.S. government and agreed to by the Department of Finance. ... S. credits, as required by paragraphs 4(b) and 5(c) of Article XXIV of the Convention, allowed for Canadian taxes paid or accrued. ... S. income tax return and the application of U.S. tax credits in accordance with Article XXIV of the Convention. ...

Dans une telle situation, s'il y a une convention fiscale entre le Canada et le pays étranger, l'article de la convention portant sur la résidence est utilisé pour établir un seul pays de résidence pour les fins de l'application de la convention et ainsi éviter la double imposition. Toutefois, lorsque les dispositions d'une convention fiscale font en sorte qu'un particulier résident du Canada pour les fins de la Loi est résident du pays étranger pour les fins de la convention, la convention ne semble pas rendre le particulier un non-résident du Canada pour les fins de la Loi. ... Comme vous le savez peut-être, le Canada n'avait pas de convention fiscale avec Hong Kong. 4. ...

Convention, Protocol, Article 6(a), Articles XII of New Canada- U. S. Convention. In Saint John Shipbuilding 80 DTC 6272 it was held that payments made to a U. ... Convention defines royalties' to mean "payments of any kind received as a consideration for the use of" certain named intangible properties, it might be thought that the difficulties presented by the Saint John case would be overcome with the entering into force of the New Convention. ...

Income Tax Convention (1942) (the "1942 Convention") and 25 percent under the Canada-U.S. Income Tax Convention (1980) (the "1980 Convention"). The case of Indalex Limited v. ... It is our view that payments under paragraph 245(2)(b) of the Act will fall within Article III (Other Income) of the 1980 Convention and will be subject to 25 percent withholding tax. ...

Income Tax Convention (1980) (the Convention) where the payment is a payment on or in respect of a copyright in respect of the production or reproduction of any literary work. ... Accordingly, Canada is required by virtue of the Convention to reduce the rate of withholding tax in respect of the computer software to 10 per cent. ... XXX We are enclosing a copy of Articles XII and XXI of the Convention together with the appropriate technical explanations for your perusal and trust this explanation of Canadian law adequately explains our position. ...