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Convention (1978) has been brought to the attention of P & I by XXXX The Problem involves a Canadian corporation borrowing Canadian dollars from a United Kingdom lender. ... Convention and because paragraph 7 of Article XI of this Convention operates to deem the interest to arise in the U.K., the interest paid is not only subject to tax in Canada, but at a 25% rate rather than the 15% rate applicable to interest arising in Canada. ... Convention XXI " " " XI- paragraph 7 of OECD model XXI ...

Harding XXXX This is in reply to your letter of October 4, 1984, concerning the Canada-United Income Tax Convention (Convention). The Department of Finance Release dated August 16, 1984, a copy of which is attached, clearly indicates that the technical explanation under date of April 26, 1984, issued by the United States Treasury Department accurately reflects the understandings reached with respect to the interpretation and application of the various provisions of the Convention. ... Since the term pension is defined for the purposes of the Convention, it is our position that the reference to "retirement" benefits in paragraph 2(a) of Article XXI should not be restricted to employees and this appears to be in line with the view expressed in the technical explanation. ...

Donnelly XXXX Dear Sirs: Re: Canada-United Kingdom Income Tax Convention (1978) This is in reply to your letter of April 6, 1981 concerning Articles 27(4), 10(3) and 28(4) of the above Convention. ... Further to your telephone request, it is our view that the tax credit referred to in Article 10(3)(b) of the Convention would be income for Canadian tax purposes in the year the dividend itself is paid. ... Hartwick Assessing Division (O A-1240-1) KJD/jb O.P.R.U.- Canada-United Kingdom Convention Articles 10, 27 and 28 ...

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. ...

Income Tax Convention (1978) (the "Convention"). Provided our understanding of the facts is correct, it is our opinion that the Canadian sourced interest paid in this transaction is interest paid to a resident of the United Kingdom in respect of a credit guaranteed by XXXX Therefore, the interest payable of XXXX in our view qualifies for an exemption under subparagraph 3(b) of Article XI of the Convention from Part XIII tax otherwise payable on that amount under the Act. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Article XI, subparagraph 3(b) Canada-U.K. Convention ...

Article X(I) of the Canada-Finland Income Tax Convention (the "Convention") states that any pension derived from sources within Canada by an individual who is a resident of Finland shall be exempt from Canadian tax. Therefore, under the Convention, no Canadian income taxes may be withheld from a pension paid to any resident of Finland. ... It was assumed that you are both residents of Finland for purposes of the Convention. ...

Short (613) 957-2134 February 25, 1991 19(1)Re: Convention Expenses Thank you for your letter of February 8, 1991. ... You have queried the deductibility of convention expenses to be incurred by 24(1) The deductibility for income tax purposes of convention expenses depends upon each individual's particular set of circumstances and can be determined only after his or her income tax return is filed and all relevant facts determined. ... Subsection 20(10) of the Income Tax Act permits a deduction in respect of expenses incurred in attending not more than two conventions per year for taxpayers who are carrying on a business. ...

Income Tax Convention ("Convention"). Paragraph 2 of Article III of the Convention states "... any term not defined therein shall, unless the context otherwise requires and subject to the provisions of Article XXVI (Mutual Agreement Procedure), have the meaning which it has under the law of the State concerning the taxes to which the Convention applies". ...

It has been our experience that seminars of this nature represent conventions. ... However, to be deductible, the expenses must be incurred in attending a convention that is held within the territorial scope of the sponsoring organization. ... For your perusal, we are enclosing a copy of Interpretation Bulletin IT-131R which discusses the deductibility of costs incurred in attending conventions. ...

Tax Convention Canada-U.S. Tax Treaty:Art. X QUESTION I 69 Withholding Tax- Dividends Paragraph 2(a) of the Article X of the Canada-U.S. Income Tax Convention reduces the rate of withholding tax on dividends if the beneficial owner of the dividends is a company which owns at least 10% of the voting stock of the company paying the dividends. ... Income Tax Convention, it is the Department's opinion that the 10% test is determined by reference to the number of issued and outstanding shares of the company which entitle the holder to a vote. ...