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Income Tax Convention on Sales of Records and Tapes by Performing Artist Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XXVI, XII, XVI Dear XXX This is in reply to your letter of July 31, 1990, wherein, pursuant to paragraph 3 of Article XXVI of the Canada-U.S. Income Tax Convention (1980), you seek to clarify the application of the said Convention with respect to income an artiste resident in one Contracting State receives that is based upon the sale of records, tapes, etc. which were recorded during a live performance in the other Contracting State. ...

Article XV of the Convention of course only applies in respect of employment income and thus has no application to the income of an independent contractor which may, however, be dealt with by Article XIV or Article VII of the Convention. Whether or not a resident of Canada is an "employer" for purposes of subparagraph 2(b) of Article XV of the Convention is essentially a question of fact. ... The individual may be paid by a United States company, but when he is the Canadian company may be an employer of the individual for purposes of this provision of the Convention. ...

Income Tax Convention September 1, 1989 International Audits Division Specialty Rulings K.B. ... Income tax Convention (1942) (the "1942 Convention") and 25 percent under the Canada-U.S. Income Tax Convention (1980) (the "1980 Convention"). The case of Indalex Limited v. ...

Tax Convention to a hypothetical situation Unedited CRA Tags 103(1), 212(1), 212(2), Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. X, XI, XXI Dear Sirs: Re: Article XXI of the Canada-U.S. Income Tax Convention (1980) (the "Convention") We refer to your letter of February 27, 1990, in which you requested our views on the application of Article XXI of the Convention to the hypothetical situation set out below. ...

7 December 1990 Income Tax Severed Letter- Canada-Netherlands Income Tax Convention on Disability Pension Unedited CRA Tags Canada–Netherlands Income Tax Convention, Art. 18 Dear XXX Re: Canada-Netherlands Income Tax Convention Article 18 This is in reply to your letter dated November 21, 1990, wherein you question the appropriateness of our Department dealing with the Dutch Ministry of Finance (the “Ministry”) concerning the nature of your XXX for the purposes of Article 18 of the XXX??? ... Paragraph 4 of Article 25 of the Convention provides that the competent authorities of the States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. ... In that case taxation in the Netherlands is limited to 15% under Article 18(3)(a) of the Convention. ...

Tax Convention, 1980. Our questions relate to the payment of royalties on Canadian resource properties to residents of the United States. Under the 1942 Convention, the Canadian tax on royalties is limited to 15%. Since royalties on resource properties are not included in the 1980 Convention's definition of royalties, the 25% tax rate under Section 212 of the Income Tax Act will apply once the relevant articles of the 1980 Convention come into force. ...

24 February 1997 Income Tax Severed Letter 9700015- Article 12 of United Kingdom Convention — videotapes Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 12 SUMMARY: Amendment to a letter (document 942143) written by Revenue Canada in 1994 regarding an interpretation of paragraph 3 of Article 12 of the Canada–United Kingdom Income Tax Convention as it applies to royalties on videotapes. ... Convention- payments for the production and reproduction of works on videotape- correction of 942143, December 20, 1994 POSITION: See letter. ...

Income Tax Convention- Determination of from What Shares Derive their Value Unedited CRA Tags Canada–U.K. Income Tax Convention Art. 13 Dear Sirs: Re: Article 13 of the Canada-United Kingdom Income Tax Convention (the "Convention") This is in reply to your letter to the Non-Resident Taxation Division dated February 12, 1991 whereby you requested an opinion regarding the application of Article 13 of the Convention. ... However, we can make certain general observations concerning our interpretation of the provisions of Article 13 of the Convention which hopefully will be of assistance to you. ...

Income Tax Convention on Non-resident Withholding Tax on Computer Programs 19(1) K. ... Income Tax Convention (1980) (the Convention) where the payment is a payment on or in respect of a copyright in respect of the production or reproduction of any literary work. ... Accordingly, Canada is required by virtue of the Convention to reduce the rate of withholding tax in respect of the computer software to 10 per cent. ...

Séguin (613) 957-8953 A l'attention de XXXXXXXXXX Le 8 septembre 1993, Monsieur, La présente est en réponse à votre lettre du 19 mai dans laquelle vous demandez notre opinion concernant une disposition de la convention fiscale conclue par le Canada avec la France (la "Convention"). ... Nos commentaires Comme vous l'avez remarqué, l'expression "personnes associées" n'est pas définie ni dans la Convention ni dans la Loi. ... En effet, il semble difficile de concevoir que des personnes ayant un lien de dépendance puissent ne pas être des personnes associées au sens de la Convention. ...