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Income Tax Convention (the Convention) as a result of an election made by the Canadian resident individual pursuant to U.S. tax law to be taxed as though he were a U.S. resident alien. ... Given that such investment income is not earned by the "S" corporation and that the individual would have dual resident status, it is our opinion that in such circumstances the Convention should apply and the amount of taxes creditable for purposes of section 126 and/or deductible for purposes of subsection 20(11) and (12) of the Income Tax Act would be limited to the maximum rate provided by the treaty. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII This is in reply to your Round Trip Memorandum dated January 1 concerning payments made to XXX, a U.S. resident) by XXX for the use of "business lists". ... Income Tax Convention, pursuant to the comments made in the Saint John Shipbuilding case (80 DTC 6272). ... Income Tax Convention. Under the new U.S. tax treaty, rental payments for the use of the list of businesses will be subject to tax at the rate of 10%. ...

Tax Convention Canada-U.S. Tax Treaty:Art. II, VIII Dear Sirs: This is in reply to your letter of January 13, 1981 concerning per diem payments for use of railroad rolling stock. ... Tax Convention. Hence, where a United States railroad corporation carries on business in Canada, such payments received from a Canadian railroad which can be reasonably attributed to that business are included in the computation of income from business within the meaning of subparagraph 115(1)(a)(III) of the Act and subject to Part I tax. ... It should be noted that when the Canada-United States Income Tax Convention (1980) becomes effective, the treatment of such payments will be the same regardless of whether the railway corporation carries on business in the "foreign" country. ...

XXX Paragraph 2 of Article III of the Canada-Belgium Tax Convention (1975) (the "Convention") provides that an individual who is a member of a permanent mission of Canada which is situated in Belgium shall be deemed for the purposes of the Convention to be a resident of Canada if he is liable in Canada to the same obligations in relation to tax on his total world income as are residents of Canada. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII 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. ... Tax Convention. The update agreement, as we understand, provides for normal updating of the copywritten material already dealt with under the license fee comments above. Provided the facts support this understanding then we are of the view that the payments made under the update agreement would be exempt by the operation of Article XIIIC of the tax convention in a manner similar to the license fee. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC This is in response to your memorandum of December 8th concerning the above-referenced U. ... Tax Convention. The update agreement, as we understand, provides for normal updating of the copywritten material already dealt with under the license fee comments above. Provided the facts support this understanding then we are of the view that the payments made under the update agreement would be exempt by the operation of Article XIIIC of the tax convention in a manner similar to the license fee. ...

Campbell   (613) 957-2067 December 1, 1989 Dear 19(1) Re:  Request for Certification In the request for certification from 24(1) of November 21, 1989 it was requested that it be confirmed that all the provisions included in the Convention between Canada and Italy are applicable to the TTA, which is the Technology Transfer Agreement. The Canada-Italy Tax Convention applies to persons who are residents of one or both of the contracting states and applies to taxes on income imposed on behalf of each contracting state. ... The Convention would apply to determine the country in which income would be taxed to regulate rates of withholding tax and generally to avoid double taxation. ...

Income Tax Convention ("the Convention"), and second, would divisions of such governments which are pension funds be eligible for the exemption provided in paragraph 2 of Article XXI of the Convention? ...

Donnelly Dear Sirs: Re: Canada-United Kingdom Income Tax Convention (1978) This is in reply to your letter of April 6, 1981 concerning Articles 27(4), 10(3) and 28(4) of the above Convention. ... Further to your telephone request, it is our view that the tax credit referred to in Article 10(3)(b) of the Convention would be income for Canadian tax purposes in the year the dividend itself is paid. ...

Donnelly Dear Sirs: Re: Canada-United Kingdom Income Tax Convention (1978) This is in reply to your letter of April 6, 1981 concerning Articles 27(4), 10(3) and 28(4) of the above Convention. ... Further to your telephone request, it is our view that the tax credit referred to in Article 10(3)(b) of the Convention would be income for Canadian tax purposes in the year the dividend itself is paid. ...