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Harding XXXX This is in reply to your letter of August 8 wherein you requested we confirm that United States shareholders of a Canadian non-resident owned investment corporation (NRO) will be entitled to the reduced rates of withholding tax provided by the Canada-United States Income Tax Convention (Convention) on income derived from the Canadian NRO. We confirm that the reduced rates of withholding tax provided under the Convention will be available to United States shareholders on income derived from a Canadian NRO. ...

In your letter you questioned whether Hong Kong would be considered as part of the United Kingdom for purposes of the Canada-United Kingdom Income Tax Convention. We have reviewed the above noted Convention and it is our view that the Convention does not cover residents of Hong Kong. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII XXX Thank you for your letter of September 18, 1985 in connection with withholding tax on certain pension and annuity payments made by Canadian payors to beneficial owners resident in the United States. ... We can advise that Article XVIII of the Convention provides that pensions arising in Canada and payable to a resident of the United States may be taxed in Canada but the tax may not exceed 15 per cent of the gross amount of such payments. ... We note that according to Article XVIII(5)(b) of the Convention one-half of the Old Age Security and Canada Pension Plan benefits received by you are exempt from taxation in the United States. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Tax Convention This is in reply to your letter of September 12, 1991 requesting confirmation of information relating to pension payments and the applicable withholding tax on these pension payments under the Canada-U.S. ... Tax Convention. In December 1991, the Department of Finance issued draft Amendments to the Income Tax Conventions Interpretation Act which addressed the question of taxation of registered retirement income fund (“RRIF”) payments to a U.S. resident. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI This is to reply to your memo of March 6, 1984 with respect to the above-captioned matter. ... Convention. In our view the property characterization of the payment in question is, for the purposes of the Convention. ... Convention exempt such payments from Canadian tax and the U. S. resident files a Canadian return of income for the year. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XV Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... It is your view that EBP payments will qualify as periodic pension payments for purposes of the Canada-United Income Tax Convention (the ""Convention") if the EBP has been set up as an unregistered pension plan and no portion of the employer's contributions relates to deferred compensation. You conclude that in accord with Article XVIII of the Convention, payments out of this type of EBP should be subject to a 15% withholding tax and that the provisions of paragraph 153(1)(a) of the Income Tax Act (the "Act") and Part 1 of the Income Tax Regulations (the "Regulations") will be restricted in their application. ...

Toussaint Dear Sirs: This is in reply to your letter dated August 12, 1985, wherein you requested our opinion on the eligibility of your client for an exemption from Canadian withholding tax on dividends under Article XXI of the Canada-United States Income Tax Convention (1980) ("Convention"). XXXX Your question is whether or not the dividends earned on Canadian securities which are purchased by the funds (via the nominee partnership) will be eligible for exemption under paragraph 2 of Article XXI of the Convention. ... Where a security is held in the name of a nominee for an organization to which a letter of exemption under Article XXI of the Convention was issued, the Canadian payer is obligated to withhold tax from any payment thereon unless the Department has provided the payer with a written authorization to refrain from doing so in respect of payments on specific securities. ...

Under Article XVII of the Canada-United Kingdom Income Tax Convention (the Convention) as it applied for 1984 and 1985, the U.K. maintained the right to tax recipients of public pensions. ... XXXX As discussed, Article XVII of the Convention has been recently changed with effect to pensions paid after April 1986. ... We enclose a copy of the revised Article XVII of the Convention for your reference. ...

1 November 1985 Income Tax Severed Letter Article XXIX- Canada-United States Income Tax Convention November 1, 1985 K.B. Harding XXXX This is in reply to your letter of October 18, 1985, concerning paragraph 5 of Article XXIX of the Canada-United States Income Tax Convention (Convention), as amended by paragraph 4 of Article XIII of the Protocol. ... Your letter indicates that the client has included the undistributed income earned in the IRA in the 1984 Canadian income tax return, however, he did not include in his United States return the income earned by a Registered Retirement Savings Plan, presumably because he made an election under paragraph 5 of Article XXIX of the Convention. ...

1 November 1985 Income Tax Severed Letter Article XXIX- Canada-United States Income Tax Convention November 1, 1985 K.B. Harding XXXX This is in reply to your letter of October 18, 1985, concerning paragraph 5 of Article XXIX of the Canada-United States Income Tax Convention (Convention), as amended by paragraph 4 of Article XIII of the Protocol. ... Your letter indicates that the client has included the undistributed income earned in the IRA in the 1984 Canadian income tax return, however, he did not include in his United States return the income earned by a Registered Retirement Savings Plan, presumably because he made an election under paragraph 5 of Article XXIX of the Convention. ...