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7 November 1990 Income Tax Severed Letter- Canada-Italy Tax Convention Unedited CRA Tags 110(1)(f)(i), 217, Canada-Italy Tax Convention Article XVIII Subject: Canada-Italy Tax Convention (the "Convention") We have been asked to reply to your memorandum of July 24, 1990 to Christine Savage, Acting Director, Provincial and International Relations Division concerning Article XVIII of the Convention which deals with pension receipts. ... Subparagraph 110(1)(f)(i) provides a deduction in computing taxable income for an amount exempt from income tax in Canada by virtue of a provision in a tax convention or agreement with another country that has the force of law in Canada. In summary for purposes of Article XVIII of the Convention, the calculation of the excess amount for purposes of the exemption and the gross amount referred to in paragraph 1(a) excludes certain pensions that are not subject to Part XIII tax. ...

Co. est-il imposable en vertu de la Convention? Vos prétentions Votre position est de considérer le gain en capital réalisé par U.S. ... Il est de notre avis que l'utilisation du terme "principalement" dans la disposition XIII(3)(b)(ii) de la Convention réfère à 50% ou plus. ... La disposition XIII(3)(b)(ii) de la Convention réfère à la notion de biens immeubles. ...

Tax Convention (the "Convention") in the following situation. ... Your position is based upon the fact that without a permanent establishment in Canada, B Co. is exempt from the provisions of Article VII of the Convention which taxes business income earned in Canada and B Co. would not qualify as an Artiste or Athlete for the purposes of Article XVI of the Convention. As such, B Co. would be exempt from tax in Canada under the provisions of the Convention. ...

Income Tax Convention on Interest and Dividend Payments 24(l) 5-9682 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 XX1 of the Convention to the hypothetical situation set out below. ... Pursuant to Article XXI of the Convention, the Funds are exempt from withholding tax under Part Kill of the Act on the interest and dividends paid to them by Canco. ...

7 August 1991 Income Tax Severed Letter- Pensions Received from Jamaica- Canada-Jamaica Income Tax Convention Unedited CRA Tags Canada-Jamaica Income Tax Convention article 19 Dear Sirs: Re: Article 19 Canada-Jamaica Income Tax Convention Request for Technical Interpretation This is in reply to your letter dated June 24, 1991 and our telephone conversations related thereto regarding a technical interpretation on the application of subparagraph 4(b) of Article 19 of the Canada-Jamaica Income Tax Convention (the "Convention"). ... Pursuant to subparagraph 4(b) of Article 19 of the Convention, pensions received from Jamaica from one of the three sources specified therein shall not be taxable in Canada so long as they are not subject to Jamaican tax. ... You have asked what is the maximum amount of pension income from Jamaica that can be received in a taxation year by a resident of Canada aged 65 or over and not be subject to tax in Canada pursuant to subparagraph 4(b) of Article 19 of the Convention. ...

Inome Tax Convention and Large Corporations Tax Unedited CRA Tags 181.1(3)(d), 181.4, Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. XXIII Dear Sirs: Re: Canada- United States Income Tax Convention, 1980 (the "Convention") and the Proposed Large Corporations Tax This is in reply to your letter dated July 13, 1990. ... Article XXIII of the Convention applies in respect of the Proposed Large Corporations Tax. 2. ...

Réponse du ministère du Revenu Quelque soit l'engagement d'une convention fiscale au niveau du droit international, il est clairement reconnu que ces conventions ont force de loi au Canada à partir du moment où Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information elles sont adoptées par une législation interne appropriée. ... Par conséquent, chaque convention fiscale doit faire l'objet d'une législation distincte pour avoir force de loi au Canada. Notons en rapport avec ceci que le paragraphe 10(6) des Règles de 1971 concernant l'application de l'impôt sur le revenu précise que toute mention dans la Partie XIII de la Loi d'un taux supérieur au taux stipulé dans une convention fiscale est, à l'égard des paiements fait à un résident de cet autre pays, interprétée comme une mention du taux stipulé dans la convention fiscale. ...

Income Tax Convention JUNE 5, 1989 Appeals Branch Specialty Rulings Appeals & Referrals Division Directorate K.B. ... Income Tax Convention 8-0293 (1980) (the "Convention") Article XII Royalties on Motion This is in reply to your memorandum of May 1, 1989 wherein you are concerned about our position not to tax royalty payments in respect to videotapes of motion picture films under the Convention. Our views, which is based on the comments in paragraph 3 of Article XII of the Technical Explanation to the Convention which states "...copyright royalties and other like payments in respect of the production or reproduction from such works on videotape... for private (home) use... ...

7 April 1991 Income Tax Severed Letter- Whether an exempt charitable organization situate in Israel is “resident of a Contracting State” for purposes of Article IV of the Canada- Israel Income Tax Convention Unedited CRA Tags Canada-Israel Income Tax Convention Article IV XXX This is in reply to your letter of March 19, 1991 in which you questioned whether we would consider an exempt charitable organization situate in Israel to be "resident of a Contracting State" for purposes of Article IV of the Canada- Israel Income Tax Convention (the "Convention"). This will confirm that for the purposes of the Convention and other income tax treaties comparable thereto we are of the opinion that an exempt organization that is created or organized in a Contracting State will generally be considered to be a "resident of" that State notwithstanding that it is granted exemption from tax in such State by the tax laws thereof. Accordingly, an exempt charitable organization that is resident in Israel will be entitled to the benefit of Article XXI of the Convention (ie. reduced withholding rate of 15%) on income arising in Canada from an estate or trust. ...

7 May 1991 Income Tax Severed Letter- Canada-France Income Tax Convention Unedited CRA Tags Canada-France Income Tax Convention article XXIX Dear Sir: This is in response to your letter of April 17, 1991, and our various conversations with respect to the deduction for Canadian income tax purposes of XXX Our understanding of the limited information provided by you is summarized as follows: 1. ... XXX You asked whether pursuant to paragraph 5 of Article XXIX of the Canada-France Income Tax Convention (1975), (the "Convention") XXX would qualify as deductible amounts paid to a pension plan that is recognized as such for purposes of the Canadian Income Tax Act (the "Act"). ... In addition, as paragraph 5 was added to the Convention by the Protocol thereto which entered into forced on October 1, 1988 and will have effect on January 1, 1989, only contributions made during the period from January 1, 1989 to the day of termination of your employee status with XXX We regret that our response could not be more favourable. ...