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Income Tax Convention- Distribution of Partnership Assets 5-8738 K.B. ... Income Tax Convention (1980)(the "Convention"). Your letter stated that you are concerned with a situation where a U.S. partnership distributes its assets to its partners, one or more (but not the majority) of whom are Canadian partners. ... Income Tax Convention (the "Convention") provides that where a resident of a Contracting State alienates property in the course of a corporate organization, reorganization, etc., the profit, gain or income in respect of such alienation may be deferred in order to avoid double taxation. ...

Income Tax Convention on Exempt Income and Alternative Minimum Tax Unedited CRA Tags 110(1)(f)(i), Canada–U.S. ... Our views The definition of taxes covered in subparagraph 2(a) of Article II of the Convention indicates that in the case of canada the existing taxes to which the Convention shall apply include those levied under Part I of the Act. As minimum tax is levied under Part I of the Act it is covered by the Convention. ...

School administrators may claim convention expenses with a maximum of 2 per year; 2. ... Paragraph 9 of IT-131R2 states that convention expenses may also be deducted by corporations recognizing that a corporation can "attend" a convention through one or more of its agents or employees. ... " Therefore, school administrators are not entitled to claim convention expenses since they are not self-employed taxpayers. ...

31 July 1990 Income Tax Severed Letter ACC9366- Canada-USSR Tax Convention- Deemed USSR Residence 19(1) G. ... If it is determined that 19(1) is a resident of the USSR under paragraph 1 or 2 of Article 4 of the Convention for a particular year, the provisions of Article 12 of the Convention will be available to him for the year. On the other hand, if it is determined that 19(1) is a resident of Canada under paragraph 2 of Article 4 of the Convention for a year, the provisions of Article 12 of the Convention will not be available to him for the year. ...

31 May 1990 Income Tax Severed Letter ACC9108- Canada-Netherlands Income Tax Convention 19(1) HBW 4125-N1 HBW 6591-N1 David Senécal (613) 957-2074 May 31, 1990 Dear 19(1) Pursuant to paragraph 4 of Article 25 of the Canada-Netherlands Income Tax Convention signed by our two counties on May 27, 1986, we would like to clarify the application of the said Convention to the following situation: A corporation, which is a resident of Canada for the purposes of the Convention, borrows Canadian dollars form a lender in the Netherlands. ... Consequently, as paragraphs 1 and 2 of Article XI of the Convention only apply top reduce the tax of 15% if the interest arises in one State and is paid to a resident in the other State and the Convention does not contain an "Other Income" article deeming the interest to be taxable only in the Netherlands where it arises, a technical interpretation of the Convention would result in the interest being subject to a 25% tax in Canada even though the interest is paid by the permanent establishment in the Netherlands. ... Therefore notwithstanding the absence of an "Other Income" provision in the Convention, we are prepared to publicly adopt the position that, under a liberal interpretation of the Convention, such interest will be exempt form tax in Canada provided you advise us that the Netherlands will adopt the some position with respect to similar transactions involving a Canadian lender and a permanent establishment of a Dutch company situated in Canada. ...

20 March 1990 Income Tax Severed Letter AC59249 F- Conventions de retraite Unedited CRA Tags 207.7, 153(1) 5- 9249 19(1) V. Plant (613) 957-8953 Le 20 mars 1990 Objet: Conventions de retraite La présente est en réponse votre lettre du 15 novembre 1989 par laquelle vous demandez 1 `opinion du Ministère aux fins de savoir qui, du dépositaire ou de l'emp1oyeur, est responsable de rémettre l'impôt remboursable sur les cotisations versées dans le cadre d'une conventiôn de retraite. VOS COMMENTAIRES Le paragraphe 207.7(1) de la Loi de l'imnôt sur le revenu (la "Loi") précise que "1e dépositaire d'une convention de retraite doit payer, pour chaque année d1imposition d'une fiducie de convention de retraite, un impôt en vertu de la présente partie égal à l'excédent éventuel de' l'impôt remboursable de la convention à la fin de l'année',' sur l'impôt remboursable éventuel de la convention à la afin de l'année d'imposition précédente". ...

Income Tax Convention — income averaging annuity contract Unedited CRA Tags 2(1), 56(1)(d), 212(1)(n), Canada–U.S. ... Income Tax Convention (the "Convention") but as Canadian resident for purposes of the Income Tax Act (the "Act"). ... The residency rules set out in Article IV of the Convention do not override the residency provisions of the Act. ...

Income Tax Convention (1980) to a particular situation Unedited CRA Tags 115.1, Canada–U.S. ... Income Tax Convention (1980) (the "Convention") to the situation described in your earlier letter of September 21, 1989. ... Income Tax Convention". In our view, section 115.1 was not enacted specifically for paragraph 8 of the Convention. ...

7 March 1991 Income Tax Severed Letter- Tax Sparing- Canada-Brazil Income Tax Convention Unedited CRA Tags Canada-Brazil Income Tax Convention Subject: XXX Tax Sparing Canada and Brazil Income Tax Convention We are writing in response to your memorandum of January 11, 1991 with which you enclosed a copy of a submission made by XXX The position being advanced by XXX is based upon a strict and literal reading of the words of the convention and, in particular, paragraph 6 of Article 11 which provides that the "limitation established in paragraph 2 shall not apply to interest arising in a Contracting State and paid to a permanent establishment of an enterprise of the other Contracting State which is situated in a third State." This "limitation" in paragraph 2 provides for a reduced rate of withholding tax in those cases in which the recipient of the interest is a "company" (as that term is defined in Article 3 of the Convention). ... In the case of the Canada-Brazil convention, it is our view the paragraph 3 of Article 22 is intended to provide tax sparing relief only in respect of interest income which has been taxed in Brazil at the reduced rates provided in paragraph 2 of Article 11 of the convention. ...

7 March 1991 Income Tax Severed Letter- Income vs. capital gains — Canada-United Kingdom Income Tax Convention Unedited CRA Tags Canada–U.K. Income Tax Convention Art. XXVII Subject: Application of Article XXVII, Paragraph 2 of the Canada-United Kingdom Income Tax Convention (the "Convention") to Capital Gains Your File No: 19023 This is in reply to your Memorandum dated January 18, 1991. We are of the opinion that Paragraph 2 of Article XXVII of the Convention does not apply to capital gains. ...