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IV 5-910837 Jim Wilson (613) 957-2120 External Technical Interpretation Inquiries This is in reply to your letter of March 19, 1991 in which you questioned whether we would consider an exempt charitable organization situate in Israel to be “resident of a Contracting State” for purposes of Article IV of the Canada-Israel Income Tax Convention (the “Convention”). This will confirm that for the purposes of the Convention and other income tax treaties comparable thereto we are of the opinion that an exempt organization that is created or organized in a Contracting State will generally be considered to be a “resident of” that State notwithstanding that it is granted exemption from tax in such State by the tax law thereof. Accordingly an exempt charitable organization that is resident in Israel will be entitled to the benefit of Article XXI of the Convention (ie. reduced withholding rate of 15%) on income arising in Canada from an estate or trust. ...

As permitted by the Convention, Revenue Canada, Taxation has entered into an arrangement with the Federal Tax Administration of Switzerland whereby we periodically provide them with copies of NR$ and NR$-A slips that show amounts paid to persons with Swiss addresses. We are of the opinion that the Convention authorizes our department to provide this information to the Swiss authorities in the manner presently being exercise. However, where the interest and dividends are remitted directly to a Lienchtenstein beneficial owner, the Convention would not apply (i.e. we would not provide the Swiss with a copy of the NR4). ...

Convention which refers to an exemption for U.K. charities from Canadian withholding tax in respect of dividends. They do, however, refer to paragraph i of Article 10 of the Convention and infer that in some way it exempts withholding on dividends paid to U.K. charities. ... However, paragraph 1 of Article 10 of the Convention does reduce the rate of withholding from 25% to 15%. ...

Tax Convention (1942), and will remain so under the greater relief provisions of Article XXX of the Canada-U.S. Tax Convention (1980) until the end of the taxpayer's first taxation year that begins on or after January 1, 1985. Thus, as in-your example, a taxpayer with an October 31 year-end would not be subject to the reduced rate of withholding under Article XII of the new Convention in respect of such payments made before November 1, 1986. ...

As a Continuing resident of Canada, any employment income earned outside the JET Programme is subject to income tax in Canada Pursuant to Article 15 of the Canada-Japan Income Tax Convention. ... Participants in the JET Programme are governed by Article 18 of the Convention and are exempt from tax in Canada based on the unique nature of the Programme. ... The initiative of and the employment by the Japanese government together with the additional responsibilty of the participants bring the participants into Article 18 of the Convention. ...

Income Tax Severed Letter ACC9219F F Unedited CRA Tags Convention Canada-Suisse — Article XVIII 5 mars 199O BUREAU DE DISTRICT DE MONTRÉAL SERVICE DE DEMANDES DE Division des Relations RENSEIGNEMENTS AUX ENTREPRISES provinciales et internationales Régent Laurin David R. Senécal Section 148, 3e étage 957-2074 HBW 4l2-S2 ARTICLE XVIII CONVENTION CANADA-SUISSE LA présente est en réponse à votre mémoire du 25 octobre 1989 dans laquelle vous nous demandez si le paragraphe 2(a) de l'article XVIII de la Convention est applicable 24(1) Nous regrettons le retard que nous avons mis a vous répondre. ... Quant à votre deuxième question, nous sommes d'avis que 24(1) Nous croyons que l'emploi 24(1) aux exemples énumérés dans les commentaires sur l'article 2 de la Convention Modèle de 1977 préparée par l'Organisation de coopération et de développement économiques (copie annexée). ...

Tax Convention Canada-U.S. Tax Treaty:Art. XXI Dear Sirs: This is in reply to your letter of August 11, 1989 in which you requested our views whether a U.S. trust that is an Individual Retirement Account ("IRA") could be exempt from Canadian withholding tax on Canadian source dividend and interest income by reason of Article XXI, paragraph 2, of the Canada-United States Income Tax Convention, 1980 ("Convention"). In our view a U.S. trust that is an IRA may qualify for the exemption provided by paragraph 2 of Article XXI of the Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. 5 Dear Sirs: Re: Permanent Establishment in Canada of a United Kingdom Corporation This is in reply to your letter of April 25 asking if, in our view, a U.K. ... Income Tax Convention (the Convention) as stated in Article V thereof, the term permanent establishment means a fixed place of business in which the business of the enterprise is wholly or partly carried on. ... In order for A to have a PE in Canada the following conditions must be met; i) there must be place of business; ii) the place of business must be fixed; iii) A must carry on business through the fixed place of business; and iv) the deeming provisions of paragraph 3 of the convention must not apply. ...

7 August 1990 Income Tax Severed Letter- Tax treatment of interest income under the Canada-Poland tax treaty Unedited CRA Tags Canada-Poland tax treaty Article 11 Dear Sirs: This is in reply to your letter of April 18, 1990 concerning paragraph 3 of Article 11 of the Canada-Poland Income Tax Convention (the “Convention”). In the opening paragraph of your letter, you indicated that interest arising in Canada and paid to a resident of Poland would be exempt from tax in Canada by virtue of paragraph 3 of Article 11 of the Convention if the interest is paid in respect of a loan that is “insured” by the Government of Canada. ... As you indicated in the telephone conversation of August 9, 1990 (Middleton XXX since paragraph 3 of Article 11 of the Convention does not have application to your particular situation, there is no need for this Division to address the other queries set out in your letter. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XXIV Dear Sirs: Re: U.S. Excess Retirement Distributions Excise Tax ("ERDET") This is in response to your letter dated November 2, 1990, wherein you requested our interpretation whether U.S. ... Income Tax Convention (the "Convention") is subject to the provisions of the law of Canada, the U.S. ERDET would also not qualify as an income tax paid to the United States for purposes of the Convention. ...