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Paragraph 1 of IT-131R2 defines a convention as a formal meeting of members for business or professional purposes. As the seminars which you propose will offer business related education to improve operations such seminars would not be considered conventions. ... (b)     The seminars you describe in your letter would be considered training and not conventions. ...

Memo to File File: 990466 Date: June 29, 1999 Simon Leung Subject: Permanent Establishment- Same or Similar activities Jan Tollovsen of Vancouver TSO inquired whether the expression "same or similar activities" used in paragraph 2 of Article VII of the Canada-United States Income Tax Convention refers to the branch or to the company as a whole. ... Support to this interpretation can be found in the commentary on Article 7 of the OECD Model Convention by Klaus Vogel in his book "Klaus Vogel on Double Taxation Convention". ... In this regard, please refer to paragraph 17.4 of the Commentary on Article 7 of the OECD Model Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI 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. ... In our opinion the word "seller" in paragraph 3(d) of Article XI of the Convention means the original seller and would not include the assignee in either of the situations you have described. If it were intended that the word "seller" include an assignee as described above it is our view that such an interpretation would have at least been outlined in the portion of the Technical Explanation of the Convention that discusses the meaning of Article XI. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII This is in reply to your letter of April 3, 1990 concerning whether certain benefits paid by the United States Railroad. Retirement Board qualify for relief under Article XVIII 5 of the Canada-U.S. income Tax Convention (1980) ("Convention"). ... However, to the extent that such benefits are those described above they will be treated as social security benefits to which Article XVIII 5. of the Convention applies. ...

Income Tax Convention. In our opinion, the above term includes recordings on video-tape which when shown on a screen are seen by the viewer as picture in movement. If the objects (the pictures) are still, the video-tape recordings are not considered to be "motion picture films" within the meaning of Article XIIIC of the Convention. ... With reference to the application of Article XIIIC of the Convention, we are not aware of any situations in which the opinion to which you refer could be said to have created on undue hardship to the taxpayers involved. ...

4 February 1980 Income Tax Severed Letter RRR14- Taxation of registered pension plan payments to a non-resident who had previously been employed by a Canadian resident at a location outside of Canada Unedited CRA Tags 2(3), 212(1)(h), 115(1)(a), Canada-Switzerland Income Tax Convention article 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. ... XXX This is in reply to your letter of January 16 concerning paragraph 212(1)(h) of the Income Tax Act and Article XVIII of the Canada-Switzerland Income Tax Convention (Convention). ... We cannot agree that the opening words of Article XVIII of the Convention could have any other meaning than a payment from a Canadian source to a resident of Switzerland in the situation you have described. ...

Income Tax Convention Art. 13, 27 September 21, 1992 Mr. E E. Campbell Acting Director Provincial and International Relations Division Revenue Canada Taxation 10th Floor, 123 Slater Street Ottawa, Ontario K1A OL8 Dear Mr. Campbell: Re: Article 27(2) of the Canada-United Kingdom Income Tax Convention This is in response to your letter of September 11, 1992 in which you requested our comments concerning the application of the above provision with respect to a capital gain that was realized by a resident of the United Kingdom from the disposition of taxable Canadian property. ... Unless Article 27(2) is applicable, the gain is exempt from Canadian tax by virtue of Article 13 of the Convention. ...

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. ...

Therefore, a payment in respect to such programming is subject to Canadian withholding tax unless it is exempt under a tax convention or agreement. ... Income Tax Convention (Convention), a payment in respect of live television programming does not constitute a royalty payment. Therefore such payments may be subject to withholding tax of 25% by virtue of paragraph 212(1)(d) of the Act and Article XXII of the Convention unless, they are considered business profits in the hand of the non-resident and the non-resident does not have a permanent establishment in Canada XXXX A.G. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI, XIII This is in reply to your letter of October 23, 1986 and further to our telephone conversation of December 5, 1986 concerning the non-resident withholding tax provisions of the Income Tax Act and the 1980 Canada-U.S. Income Tax Convention with respect to the above noted bond issues. You advised over the telephone that both issues took place before April 16, 1966. ... Income Tax Convention, the rate of withholding on interest payments made to U.S. residents, was reduced from 25% ro 15%. ...