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Provincial and International Relations Division have indicated that such arrangements on social security do not override the Act and would also have no effect on income tax agreements or conventions. The only tax agreement or convention which we are aware of which overrides the Act concerning social security payments is paragraph 5 of Article XVIII of the Canada-U.S. Income Tax Convention (Convention). In the case of the United States, we have indicated that, in the calculation of taxable income of a U.S. resident under section 217 of the Act, the individual would be permitted a paragraph 110(1)(f) deduction win respect of benefits received from OAS and CPP/QPP pursuant to paragraph 5 of Article XVIII of the Convention. ...

4 February 1981 Income Tax Severed Letter RRRR34- Canada-Australia treaty — treatment of capital gains and dividends Unedited CRA Tags 2(3), 115(1)(b), 84, 212.1, Canada–Australia Income Tax Convention Dear XXX This is in reply to your letter of December 29 concerning the Canada-Australia Income Tax Convention (1980) (the Convention) which has yet to be ratified. ... We agree that in the absence of the effect of a tax convention, subsection 2(3) of the Income Tax Act would apply and tax would be payable by Mr. and Mrs. ... We have perused the Convention and there is no specific Article dealing with the alienation of capital property you have described. ...

7 December 1991 Income Tax Severed Letter- Employment income earned while on an aircraft in international traffic Unedited CRA Tags Canada-Switzerland tax convention Articles XV, III Canada- Switzerland Tax Convention Article XV, Paragraph 3 This is in reply to your memos dated November 28 and December 3, 1991 regarding the above matter. ... Paragraph 3 of Article XV of the Canada- Switzerland Tax Convention (the "Convention") states that, notwithstanding the preceding provisions of that Article (Dependent Personal Services), remuneration in respect of an employment exercised aboard on aircraft operated in international traffic by an enterprise of a Contracting State, shall be taxable only in that State. ... It would be easier to make a case that the above result was not intended if the language of the subject Article was peculiar to the Convention, however this is not the case. ...

Income Tax Convention Art. 13 922996 XXXXXXXXXX Jim Wilson (613)957-2123 Attention: XXXXXXXXXX December 11, 1992 Dear Sirs: Re: Canada-U.K. Income Tax Convention (the "Convention") We are writing in reply to your letter dated September 29, 1992, in which you requested our comments on the application of paragraph 9 of Article 13 of the Convention under the following hypothetical set of facts: Facts 1. ... Our Comments Based on the understanding that the taxpayer, immediately after his departure from Canada, will be a resident of the U.K. for purposes of the Convention as defined in Article 4 therein, paragraph 9 of Article 13 of the Convention will not apply. ...

It is our understanding that you are concerned with the treatment of such a gain and the related foreign tax credits provided in Article XXIV of the Canada-United States Income Tax Convention (Convention). ... However, paragraph 3(a) of that Article states that Canada and the United States must respect certain provisions of the Convention. ... Article XXIV- Canada-United States Income Tax Convention (new) Article XIII- Canada-United States Income Tax Convention (new) ...

Income Tax Convention (Convention) does not restrict his client from claiming a foreign tax credit on the full amount of the tax paid to the United States. Paragraph 4 of Article XXIV of the Convention provides that Canada shall allow a deduction from Canadian tax in respect of income tax paid or accrued to the United States in respect of profits or income arising in that country. ... Paragraph 6 of Article XXIV of the Convention will deem taxes paid on income earned in the U.S. to arise in Canada to the extent necessary to avoid double taxation of such income. ...

Income Tax Convention (Convention). Subsection 212(1)(b) of the Income Tax Act (the "Act") requires every non-resident of Canada to pay an income tax of 25% of every amount that a resident of Canada pays or credits to him. ... Since Paragraphs 1 and 2 of Article XI of the Convention do not deal with interest arising in a third country and paid to a resident of the United States, such an item of income will fall within Paragraph 1 of Article XXII of the Convention. ... It should be noted that such an exemption is applicable to this particular Convention and its application to other income tax convention or agreements may not produce the same result. ...

Income Tax Convention Art. 11 RE: Withholding Tax on Subsidiary Deposits with Foreign Branches This is in reply to your memorandum of March 10, 1987 concerning withholding tax under Article XI of the Canada-United Kingdom Tax Convention (Convention). ... The Convention does not contain any other provisions that could deal with such income. ... The purpose of the Convention is to avoid double taxation for residents of the Contracting State. ...

Tax Convention (the “Convention”) in the following situation. We apologize for the delay in responding to your request. 1. ... Your position is based upon the fact that without a permanent establishment in Canada, B Co. is exempt from the provisions of Article VII of the Convention which taxes business income earned in Canada and B Co. would not qualify as an Artiste or Athlete for the purposes of Article XVI of the Convention. As such, B Co would be exempt from tax in Canada under the provisions of the Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII, XXII XXXX E. Wayne Hood Tel. (613) 993-7295 November 27, 1984 XXXX This is in reply to your letter of September 11 concerning the Convention Between Canada and The United States Of America With Respect To Taxes On Income And On Capital (the Convention). ... The Income Tax Act imposes a withholding tax of 25% (which is not reduced by the Convention). 4. ... Article XVIII of the Convention also exempts these payments from Canadian income tax. ...