Search - convention

This individual, once or twice per year, attends a convention sponsored by the Master Franchisor of his employer. ... The individual pays all costs associated with his attendance at such conventions. ... As a consequence, the convention expenses would not be deductible under paragraph 8(1)(f) of the Act. ...

Income Tax Convention (1942) Income Tax Convention Interpretations Act------------------------------------------ This is in reply to your letter of February 15, 1985 wherein you requested confirmation of your understanding of the interaction of the above-referenced laws. ... USCO B does not have a permanent establishment in Canada, as that term is defined in and for the purposes of the 1942 Convention. 2. ... Tax Convention (1942) are applicable. Consequently, a withholding tax must be paid on the deemed dividend. ...

-Canada Income Tax Convention (1980) (the "Convention"), U.S. Co. is considered to be a resident, for purposes of the Convention, of the U.S. only. ... 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 U.S. ...

Pour être une convention de retraite (la "convention"), un régime ou un mécanisme doit prévoir une "cotisation" par un employeur. ... En vertu du paragraphe 207.6(2) de la Loi, le contrat de rente est le bien déterminé et sera réputé être le bien de la convention. Ainsi, en vertu du paragraphe 207.6(1) de la Loi, le bien déterminé de la convention est réputé être détenu en fiducie et le dépositaire de la convention est réputé être le fiduciaire de la fiducie. ...

Income Tax Convention (1978) (the "convention") in the context of the hypothetical fact situation described below. ... All of the assets of Opco constitute property other than immovable property. within the meaning of Article XIII of the Convention. ... However, we are not in agreement with your views as to the interpretation of that provision of the Convention. ...

Your assessments for 1984 and 1985 have made allowance for the exemption provided in the Convention. ... For the period from January 1, 1986 to April 5, 1986 Article XVII of the Convention as it read prior to the amendment would apply to the payments you received from XXX. ... Please find attached the relevant provisions of the Convention. We hope the above is of assistance to you. ...

Your assessments for 1984 and 1985 have made allowance for the exemption provided in the Convention. ... For the period from January 1, 1986 to April 5, 1986 Article XVII of the Convention as it read prior to the amendment would apply to the payments you received from XXX. ... Please find attached the relevant provisions of the Convention. We hope the above is of assistance to you. ...

Tax Convention (1980), where applicable, does modify the position outlined in 1 above. ... In this context, see Article IV of the Convention. (c) A U. S. resident consulting firm that has employees who are providing services in Canada, whether a proprietorship, partnership or corporation, would normally not be subject to the provisions of Articles XIV and XVII of the 1980 Convention. ... In the event of any inconsistency between provisions of the Act and an international tax convention, the provisions of the convention will normally prevail. 5. ...

Income Tax Convention (1978) (the "Convention") in the context of the hypothetical fact situation described below. ... All of the assets of Opco constitute property other than immovable property, within the meaning of Article XIII of the Convention. ... However, we are not in agreement with your views as to the interpretation of that provision of the Convention. ...

Income Tax Convention (the 'Convention') with respect to taxes to be withheld in 1987 from XXXX tier I and tier 2 benefit payments for you and your spouse. It is assumed that you are both Canadian residents for purposes of the Convention. ... Your foreign tax credit is limited to the amount allowable by the Convention. ...