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Tax Convention (the Convention) to the distribution by F. It is our view that a distribution of assets by way of a dividend in kind is an exchange within the meaning of Article VIII of the Convention. ...

Our point was that under the 1942 Convention the purposes for which information can be supplied are limited. ... While we do not wish to appear to be cavilling, it has always been our position that the 1942 Convention did not cover collection matters. ... The 1980 Convention is broader and we have no difficulty in assisting in regard to years covered by it. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII, XXX(5) Dear XXX This is in reply to your letter of November 26, 1984 in which you ask whether the provisions of section 212 of the Income Tax Act (the "Act") apply in the circumstances described. ... Income Tax Convention (the "Treaty"), although the Treaty reduces the rate of tax to 10%. ... Income Tax Convention, use payments for television programs originally recorded on videotape are exempt from withholding tax. ...

Treasury Department's Technical Explanation rather than amend the Convention. ... Given this background and the fact that the Second Protocol to the Canada-United Kingdom Income Tax Convention amends paragraph 4 of Article XII by adding the word "broadcasting" after the phrase "for use in connection with television" it can be concluded that the same intention should be ascribed to the relevant words in the United States Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC XXX This is in reply to your letter of September 9, 1981 concerning royalties paid to U.S. residents with respect to programs supplied on videotapes. ... Income Tax Convention would exempt the U.S. residents from Canadian income tax on royalties paid for the use of videotapes of TV programs, provided the U.S. resident is not engaged in trade or business in Canada through a permanent establishment. ... Tax Convention (not yet ratified) contains provisions which will cancel the above-mentioned exemption and subject such previously exempted royalties to Part XIII tax at the rate of 10%. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Dear Sir: This is to reply to your letter of June 4, 1984 relating to the above-captioned matter. ... Convention which is currently in force or the exemption contained in subparagraph 212(1)(d)(vi) of the Act to such payments paid or credited the non-resident person. ... Convention will operate to exempt from tax awards of damages or payments pursuant to out of court settlements made in connection with the wrongful misappropriation of copyrights, since both provisions refer to payments made pursuant to the terms of consensual agreements. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII(3), XIIIC Dear Sirs: This is in reply to your letter of December 3, 1984 concerning royalties paid to U.S. residents for the use or right to use videotapes on aircraft in Canada (i.e., domestic flights). ... Income Tax Convention (1980) (and Article XIIIC of the previous convention), it is our view that a royalty paid for the use of a videotape of a motion picture film is a "royalty in respect of a motion picture film". ...

Income Tax Convention (1978) and the Canada-U.S. Income Tax Convention (1980), the term "pension" includes any payment under a... retirement plan... ... Tax Conventions. For the purposes of the tax treaties that Canada had entered into with countries other than the U.K. and the U.S., it is our view that periodic payments out of an RRSP or a RRIF would normally represent periodic annuity payments. ...

Income Tax Convention Art. 13(7)(b) Dear Sirs: Re: Article 13 of the Canada-United Kingdom Income Tax Convention (the “Treaty”) This is in reply to your letter dated August 24, 1990 whereby you requested our opinion concerning subparagraph 7(b) of Article 13 of the Treaty. ... Generally, subject to any special provisions such as paragraph 4 of Article 13 of the Treaty, our opinion set further above in respect of subparagraph 7(b) of Article 13 of the Treaty will also apply in respect of comparable provisions of other income tax conventions. ...

7 February 1991 Income Tax Severed Letter- Withholding tax on license fee Unedited CRA Tags Canada-Korea Income Tax Convention Dear XXX This is in reply to your letter of this date requesting information with respect to the possibility of the Korean tax authorities subjecting a license fee, to be paid to your company by a Korean company, to a withholding tax. ... Senecal of this division, we are of the view that there is no provision in Canada-Korea Income Tax Convention which would prevent Korea from taxing a royalty payment to a resident of Canada solely on the fact that the fee was paid in the form of a lump sum amount rather than a series of periodic payments. We also confirm that the Convention does not provide an exemption for payments of license fees involving “new advanced technology”. ...