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30 April 1985 Income Tax Severed Letter 0-230B Unedited CRA Tags 116, 212(1)(d) As a result of the recent ratification of the Canada-United States Income Tax Convention, 1980, ("the 1980 Convention"), we are reviewing our present treatment of delay rentals paid to non-residents. ... Because Article VI of the 1980 Convention now permits us to tax U. S. Recipients of such amounts under Part 1 or Part XIII (compare Article VIII of 1942 Convention- Part XIII route only available), we are in a position, if we desire and it is practical to do so, to introduce consistent Part I taxation of these amounts after 1985 for both residents and non-residents. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VII, XIV, Canada–U.K. Income Tax Convention Art. 7, 14 XXXX M. ... It is our opinion that reasonable management fees paid to a person resident in the United States will fall within Article VII or Article XIV of the Canada-U.S. 1980 Tax Convention and reasonable management fees paid to a resident of the United Kingdom will fall within Article 7 or Article 14 of the Canada-U.K. Convention. Accordingly, such fees would only be taxable in Canada if the United States or United Kingdom resident, as the case may be, carries on business in Canada through a permanent establishment or fixed base situated in Canada, and only to the extent the fees are attributable thereto. ...

Tax Convention We have recently been informed by an international accounting firm that the U. ... Tax Convention to be applicable to computer software payments paid by a U. ... In particular, we are interested in knowing whether Revenue Ruling 66-55 or any other Rulings are relevant to Article XIIIC of the Convention. ...

Income Tax Convention (1980) and the Canada-France Income Tax Convention (1975) to exempt from Part XIII withholding tax, royalties payable by a Canadian distributor to either an unrelated U.S. producer corporation or to an unrelated French producer corporation for the right to distribute in Canada various videotapes and videodisc products for home use. ... Income Tax Convention (1980), royalties exempt pursuant thereto include royalties related to the sale or rental of videotapes for private viewing. ... For the purposes of Article XII(3)(a) of the Canada-France Income Tax Convention (1975), royalties exempt pursuant thereto also include royalties related to the sale or rental of videotapes for private viewing. 3. ...

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 NR4 and NR4-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). ...

30 April 1985 Income Tax Severed Letter 0-230 F RE: Delay Rentals Paid to Non-Residents As a result of the recent ratification of the Canada-United States Income Tax Convention, 1980, ("the 1980 Convention"), we are reviewing our present treatment of delay rentals paid to non-residents. ... Because Article VI of the 1980 Convention now permits us to tax U. S. Recipients of such amounts under Part 1 or Part XIII (compare Article VIII of 1942 Convention- Part XIII route only available), we are in a position, if we desire and it is practical to do so, to introduce consistent Part I taxation of these amounts after 1985 for both residents and non-residents. ...

Ltd. would be considered to be a resident of the United States for the purposes of the Canada-United States Income Tax Convention and a resident of the United Kingdom for the purposes of the Canada-United Kingdom Income Tax Convention. ... Ltd. would have a wholly-owned Canadian subsidiary (Canco) which would pay dividends and have other dealings with its non-resident parent company to which the provisions of both Conventions might be applicable. We agree with your suggestion that the companies should be free to choose which of the two Conventions should apply in such cases. ...

Harding XXXX Dear Sirs: This is in reply to your letter of September 18, 1984, concerning Article XXX of the Canada-United States Income Tax Convention (Convention). ... However, since paragraph 6 of Article X of the Convention limits the rate of additional tax to 10 per cent of branch earnings, we are of the view that the requirement of subparagraph 11(4)(a) has not been met and, accordingly, the branch tax will not be reduced to 10 per cent prior to the period set out in paragraph 2(b) of Article XXX of the Convention. ...

We have reviewed the Canada-Australia Income Tax Convention, and it is our view the Australian payers are withholding the appropriate rate of tax on dividend and interest based on the information submitted. The Canada-Australian Income Tax Convention does not provide an exemption for dividends and interest received by pension fund trusts similar to Article XXI of the Canada-United States Income Tax Convention. ... You may wish to review the Australian Income Tax Act or contact the Australian authorities to determine whether they have exceptions to the general rule set out in the Canada-Australia Income Tax Convention. ...

Income Tax Convention (1980) (the "Convention") and to delete therefrom the portion reported as interest. ... It is our position that for purposes of the Convention, amounts received out of an IRA will be a payment from a retirement plan and as such fall within Article 18 of the Convention. ...