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Tax Convention Registered Retirement Savings Plan XXXX Dear Sir: We are writing to you to seek your interpretation of the application of Part XIII of the Income Tax Act and the Canada- U.K. Tax Convention with respect to payments under a registered retirement savings plan (the "plan"). ... Tax Convention provides: "any pension... or any annuity derived from sources within one of the territories by an individual who is a resident of the other territory shall be exempt from tax in the first-mentioned territory" It seems clear that an annuity purchased under the plan is an annuity for the purposes of paragraph 1 of Article 16. ...

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 has 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. ...

Harding (613) 957-2129 19(1) This is in reply to your letter of September 28, 1989 wherein you requested clarification of your income tax status for 1989. 24(1) Pursuant to paragraph 250(1)(c) of the Income Tax Act (the Act) a non-resident of Canada will be deemed to be a resident of Canada throughout a taxation year if he was at any time in the year an ambassador, minister, high commissioner, officer or servant of Canada and (a) he was a resident in Canada prior to appointment or employment by Canada or (b) he received representation allowance in respect of the year 24(1) Paragraph 2 of Article XXVII 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 resident of Canada. 24(1) In Summary, you will be taxable for the 1989 and subsequent taxation on your world income in Canada if you continue to work in your present capacity. ...

Income Tax Convention (the "Convention") is subject to the provisions of the law of Canada, the U.S. ERDET would also not qualify as an income tax paid to the United states for purposes of the Convention. ...

Income Tax Convention (1980). In this regard you have asked us to confirm that where a non-resident corporation has several construction contracts with respect to multiple construction sites in Canada, we would not consider the corporation to have a permanent establishment in Canada for the purpose of Article V of the Convention solely on that basis. ... Normally, in making such a determination, the Department would give consideration to the commentary on paragraph 3 of Article V in the Model Double Taxation Convention On Income and On Capital-Report of the OCED Committee on Fiscal Affairs 1977. ...

In Canada, the provisions of the tax convention with the Ivory Coast will generally apply to taxes on superannuation benefits pertaining to the year following the year in which the convention enters into force. ... In the case of the tax convention with Bangladesh, its provisions will generally apply in Canada from 1982. Note: Tax Conventions will be signed in the near futurewith Brazil, Cyprus, India and Thailand. ...

In Canada, the provisions of the tax convention with the Ivory Coast will generally apply to taxes on superannuation benefits pertaining to the year following the year in which the convention enters into force. ... In the case of the tax convention with Bangladesh, its provisions will generally apply in Canada from 1982. Note: Tax Conventions will be signed in the near future with Brazil, Cyprus, India and Thailand. ...

18 December 1989 Income Tax Severed Letter RCT-0130 Unedited CRA Tags Canada-Australia Tax Convention article 25 Dear XXX XXX It would be appreciated if you could give us your comments on this matter. ... This request is made pursuant to Article 25 of the Canada-Australia Tax Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII Section 212.1- Article XIII of Canada- U.S. Convention Your memorandum (prepared by R.C. O'Byrne) dated March 14, 1989 was send to Finance for their comments. ...

Income Tax Convention (the "U.S. Convention")? Department's Position 1. ... Convention. Such a determination can only be made on a case by case basis. ... Convention and Art. 5 & 15 of OECD Model-Sections 115(1), 248(1) & 253 ...