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It was suggested I refer the attached files to your attention: Italy Tax Convention XXXX United Kingdom Tax Convention In both these Conventions, professors are included in the article for Professionals. ...

Income Tax Convention (1980) (Convention) Section 115.1 of the Income Tax Act Deferrals on Dispositions of Property by Non-Residents Corporate Winding-up Our Division is responsible for administering the prescribed tax treaty provision referred to in section 115.1. We would appreciate having your opinion as to whether a wind-up (liquidation) of a corporation which involves the distribution of its assets to its sole shareholder, an individual, is "a corporate organization, reorganization, amalgamation, division or similar transaction" for the purposes of Article XIII(8) of the Convention. ...

Tax Convention Further to my conversation with Ms. Carol Toussant of your department of today's date, I am writing to request your opinion on the following matter: Whether under the Canada-U.S. Tax Convention, 1980 a U.S. resident beneficiary of a Canadian resident estate would be able to employ the withholding tax exemption in Article XI.3(b) of the Convention when receiving amounts from the aforementioned estate. ...

Tax Convention According to Article XX of the Canada- U.K. Tax Convention, the lower rate of 15% is applicable only on income received by a resident of the United Kingdom who is the beneficial owner thereof from an estate or trust resident in Canada. Article XXVII, paragraph 2 appears to provide relief from tax to be allowed under the Convention only with respect to income amounts so remitted or received. ...

Donnelly (613)995-0038 This is in reply to your letter of January 23, 1981 concerning sub-paragraph 4(a) of Article XIII of the Canada-United Kingdom Convention which came into force on December 17, 1980. ... While these exemptions may be indicative of policy, in the absence of a specific exclusion we must interpret the very clear wording of the Convention as it is written. ... Yours sincerely, Director Provincial and International Relations Division KJD/jb Canada-United Kingdom Convention Article XIII ...

K1A 2L8 Gentlemen: The Canadian Income Tax Act, and the Canada-United States Income Tax Convention, appears to limit, as a deduction from taxes otherwise payable, to 15% that U.S. tax incurred on income from property. ... Although the new Convention, on the one hand, appears to limit the U.S. tax, in this instance, to 15% (Article XI), according to Article XXIX-2 the U.S. may tax its citizens as if there were no convention, therefore, it would appear that this inequity will continue. ...

Arsenault (613) 957-2126 19(1) Feb 14, 1991 Dear Sirs: Re: Article XII of the Canada-United States Income Tax Convention. 1980 (the "Convention") This is in reply to your letter dated December 17, 1990. In our opinion, a payment arising in Canada made by a Canadian resident to a person resident in the United States (who does not have a permanent establishment in Canada) for services of an industrial, commercial or scientific character performed by the resident of the United States for the Canadian resident, which payment is dependent in whole or in part upon use, production or sales of goods or services, or profits and is a payment to which subparagraph 212(1)(d)(iii) applies, is not a "royalty" as defined in paragraph 4 of Article XII of the Convention. ...

Income Tax Convention (the "Convention). Since the total of the remuneration for the 1989 calendar year, including the portion of benefit received by Mr. ... Income Tax Convention and the results may differ where the wording of either the de minimus rule or the 183 day rule in other tax treaties are different from that in the Canada-U.S. Income Tax Convention. ...

Income Tax Convention. Position: The Article XXI exemption would not apply to the U.S. master trust. ... Income Tax Convention (the “U.S. Convention”). There was insufficient information given in XXXXXXXXXX letter to fully understand: the proposed structure; the residency of the investors; or the amounts and types of Canadian investment income derived in Canada; etc. ... Convention, or the reduced withholding rate of tax accorded to amounts paid to residents of the U.S. under provisions in the U.S. ...

Income Tax Convention (Convention). Accordingly, payments made by XXX under the Program License Agreement to XXX a corporation organized the laws of XXX would be subject to 10 per cent withholding tax. ... If the non-resident payee is considered to be a resident of the U.S. for purposes of the Convention, such payee will be exempt under Article VII of the Convention, from Canadian tax on the business profits earned from the provisions of the services unless the payee carries on business in Canada through a permanent establishment in Canada and the profits are attributable to such permanent establishment. A payee who is exempt from Canadian taxation by virtue of Article VII of the Convention may obtain a refund of taxes withheld under Regulation 105(1) by filing a Canadian tax return (note that Article VII in the Convention does not prohibit the initial withholding under Regulation 105(1) but does entitle a payee who is exempt thereunder from Canadian tax to obtain a refund of amounts so withheld). ...