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Income Tax Convention (1980) (the "Convention") in the context of the following set of hypothetical facts: 1. ... Accordingly, paragraph 2 of Article XI of the Convention would give Canada the right to tax such interest. However, the rate of 25% otherwise withheld under subsection 212(1) of the Act would be reduced to 15% by Article XI of the Convention. ...

Income Tax Convention (the "U.S. Convention"). Your particular situation concerns a taxpayer who is a citizen of the United States. ... Convention do not override the deeming provisions of paragraph 250(1)(a) of the Act. ... Convention. The taxpayer can then look to subparagraph 110(1)(f)(i) of the Act for a deduction of those amounts. ...

Income Tax Convention (1980) (the "Convention") for its fiscal year commencing January 1, 1985.- Due to the operation of paragraph 3 of Article IV of the Convention, USCo is deemed to be a resident of the U.S. for the purposes of the Convention. ... Therefore, as of January 1, 1986 USCo will not be considered a resident of Canada for the purposes of either the Convention or the Act. ... However, since a deemed disposition under section 48 of the Act is considered to be an alienation of property for the purposes of the Convention, paragraph 4 of Article XIII of the Convention would exempt USCo from taxation in Canada on any gain arising on this deemed disposition other than gains on the alienation of either real property situated in Canada or personal property forming part of the business property of a permanent establishment in Canada (as detailed in paragraphs 1 through 3 of Article XIII of the Convention). ...

Generally speaking the conventions permit the exchange of information for the purpose of administering domestic taxation laws of the contracting states as defined in the convention, although in one instance that is restricted to the administration of the convention. ... Restrictions in our domestic legislation are overidden by the tax convention. We would hope that some paramountcy could be given to the conventions. ...

Retraite-Décès); doit être désignée comme une entente d'échelonnement du traitement ou de convention de retraite. ... En l'absence d'une telle disposition, la convention de retraite serait un régime de prestations aux employés. ... Pour l'application des dispositions de la Loi concernant les conventions de retraite, un régime qui existait le 8 octobre 1986 sera considéré comme deux régimes distincts à la date où la définition est applicable conformément à la règle transitoire énoncée plus haut: soit la convention de retraite, nouveau régime réputé à être établi à cette date, et le régime initial qui n'est pas une convention de retraite. ...

Income Tax Convention Art. 17, 20 July 10, 1985 Accounting and Collections Division Non-Corporate Rulings Division Glen Thornley 995-2455 A. ... Tax Convention (1980) (the Convention). Included with the attachment from Toronto isXXXX. ... Convention Para. 212(1)(1) ...

Income Tax Convention Art. VII XXX This is in reply to your memorandum dated March 29, 1984 concerning the exigibility of Part XIII tax on management fees paid to a U.K. affiliate of the above-noted Canadian corporation. ... Tax Convention (1978). (Unlike the Canada-US Tax Convention of 1942 the Canada-UK Convention does not exclude management charges from industrial and commercial profits.) ... In fact there may be an argument that Article IX of the Convention would support this approach. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XV(2)(b) Dear Sirs: Re: Article XV(2)(b) of the Canada-United States Income Tax Convention, 1980 (the “Convention”) This is in reply to your letter dated December 6, 1990. Your proposed representation of the Department's position concerning the application of the above-noted provision of the Convention where a United States parent company (“U.S. ... In our opinion, whether or not a resident of Canada is an “employer” for purposes of subparagraph 2(b) of Article XV of the Convention is essentially a question of fact. ...

7 November 1990 Income Tax Severed Letter- Taxation by Spain of Fees Earned by Canadian Firm Unedited CRA Tags Canada-Spain Income Tax Convention articles 1 and 7 Dear XXX This is in reply to your letter of November 21, 1990, concerning taxation by Spain of fees earned by your company with respect to a contract to be entered into by your firm to provide XXX We are not aware of any special tax concessions adopted by the Spanish Government with respect to foreign companies performing work for the XXX However, Article 7 of the Canada-Spain Income Tax Convention (copy attached) does provide that the business profits of a Canadian enterprise are only taxable in Canada unless the enterprise has a permanent establishment in Spain. ... Article 1 of the Convention (copy attached) provides that the Convention shall apply only to residents of one or both of the Contracting States. In as much as a resident of a Contracting State is defined in the Convention as being any person liable to tax in that State by reason of residence, place of management, etc., the Spanish tax authorities have the right to ask that the Canadian tax authorities confirm that your company is a resident of Canada and liable to tax here prior to granting any relief provided for in the Convention. ...

Tax Convention- 3(d)). Additionally, we do not view the Canadian subsidiary as falling under the exclusion found in paragraph 4 of the Convention "... unless his activities are limited to the purchase of goods... ... Tax Convention dealing with "resident of a contracting state". ... Convention ...