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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. ... 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%. ...

Short: Re: Article XXII, Canada-United Kingdom Income Tax Convention (Convention) Mr. Hans Braeuel of our Tax Avoidance and Foreign Operations Division has sent us a memo concerning the "non-discrimination" clause in the above Convention in the following situation. ... It is our view that paragraph 1 of Article XXII of the Convention does permit discrimination between residents and non-residents since they would not be considered in the same circumstances as is required by that paragraph, however, Canada does not discriminate between non-resident taxpayers. ...

Ravis: Thank you for your letter of November 9, 1984, and the attachment which you received from your constituent XXXXXXXX In December, 1980, a revised Tax Convention entered into force between Canada and the United Kingdom, and enclosed is a copy of Article 17 of this Convention which deals with the subject of pensions and annuities. ... However, there is a provision in the Convention and in the Canadian Income Tax Act for a foreign tax credit which is a deduction from Canadian income tax in respect of part or all of the United Kingdom tax paid by Canadian taxpayers on pension or annuity income which is sourced in the United Kingdom. ... The Convention also contains a provision which exempts the first $10,000 Canadian or £5,000 Sterling of the total annuity or pension payments, whichever is the greater, from taxation by the source country. ...

Harding XXXX This is in reply to your letter of September 28, 1984, concerning the Canada-United States Income Tax Convention (Convention). ... Accordingly, you will probably have to contact the Internal Revenue Service in the United States and request what procedures are required to obtain the tax exempt status under the Convention. It is our understanding that the United States is presently establishing a certification process to ensure that only qualifying Canadian taxpayers may obtain benefits under the Convention. ...

Paragraph 1(a)(ii) of Article III of the present Canada-United Kingdom Income Tax Convention which entered into force on December 17, 1980, states: "the term "United Kingdom" means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which in accordance with international tax law has been or may be hereafter designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea-bed and sub-soil and their natural resources may be exercised. ... ", the Department of Finance have advised us that neither the Agreement nor the Convention have been extended beyond the scope set out in the above two definitions of the term United Kingdom. ... Lucia may have which indicates that either the Agreement or Convention has been extended to St. ...

9 May 1986 Income Tax Severed Letter MAY 9 1986 XXXX Thank you for your letter of February 20 in which you enquire about Article 22 of the new Canada-Brazil Income Tax Convention. ... If this is so, paragraph 6 of Article 11 of the Convention will affect the application of paragraph 2 of that Article with the result that Brazil may tax the interest at whatever rates it chooses without being limited to the rates prescribed by paragraph 2. ... We need not remind you, of course, that the ordinary foreign tax credit under the Income Tax Act may be claimed if it is greater than the amount determined under the Convention. ...

Charron le 15 février, 1977 Cher XXXX, En réponse à votre lettre, concernant les impôts sur les revenus, exécution de la convention belgo-canadienne nous désirons vous sousmettre les renseignements suivants: 1. Vous trouverez ci-joint notre circulaire d'information 76-12 qui a trait aux taux applicables de l'impôt de la Partie XIII sur les sommes payées ou créditées aux personnes qui vivent dans les pays ayant des conventions fiscales avec le Canada. ... L'article X de la convention belgo-canadienne prévoit que le taux maximal de la retenue à la source canadienne sur les dividendes payés à des bénéficiaires effectifs belges sera de 15% de leur montant brut. ...

Paragraph 8 of Article XXVIII of the Canada-United Kingdom Tax Convention (1978) only requires Canada to ignore the time limitations (set out) in the Income Tax Act if the application is made within one year of the end of the calendar year in which the Convention entered into force. The Convention entered into force on December 17, 1980. Accordingly, Revenue Canada, Taxation would be prepared to adjust these returns for the 1976 and subsequent taxation years, pursuant to Article XXVIII of the Canada-United Kingdom Tax Convention, provided the returns are not statute-barred at the time the request is made. ...

Watson 957-2072 FILE HBW 4125-U3-2 SUBJECT: CANADA-UNITED STATES INCOME TAX CONVENTION (1980) ("THE CONVENTION") The question of whether a division of the federal, state or local government of the United States, which is constituted exclusively to administer or provide benefits under one or more funds or plans established to provide pension, retirement or other employee benefits, would be eligible for the exemption from withholding tax on dividends and interest received from Canadian sources pursuant to the exemption provided in paragraph 2 of Article XXI of the Convention was explored with Internal Revenue Service officials. We were advised that a division of the federal, state or local government would be treated as resident of its respective state for purposes of the Convention. ...

We have also noted that the 1981 Round Table position was formulated before the introduction of the Income Tax Conventions Interpretation Act ("ITCIA"), which is applicable, in the case of tax under Part XIII of the Act, to amounts paid or credited after June 23, 1983. Under the ITCIA, if a term is not defined in the provisions of a convention, it has the same meaning it has for the purposes of the Act. ... Conversely, of the payments are described in a definition of rentals in the applicable tax convention, then the payments to the non-resident, in respect of a lease regarded as a disposition of property under the Act, would be rental payments. ...