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Harding (613) 957-2111 September 28, 1993 Dear Madam: Re: Canada-Egypt Income Tax Convention (the "Convention") This is in response to your fax (the "Fax") dated September 22, 1993 concerning the treatment of the income of Canadian partners who are members of an Egyptian partnership which carries on business in Egypt and not in Canada. ... As indicated in our letter of September 14, 1993 the Income Tax Conventions Interpretation Act ("ITCIA"), which was passed in Parliament and received Royal Assent, was enacted to ensure that the interpretation of any of Canada's tax treaties would not prevent Canada from taxing its residents on their world income. ...

Income Tax Convention (1980) ("Convention"). We understand that the benefits in question are those Tier 1 Benefits that are equivalent to the U.S. social security benefits that railroad employees would otherwise be entitled to receive if their service had been covered under the U.S. social security system. ... However, to the extent that such benefits are those described above they will be treated as social security benefits to which Article XVIII 5. of the Convention applies. ...

23 January 1984 Income Tax Severed Letter A-9141 Unedited CRA Tags 212(1)(d), Canada-Israel treaty article III Dear Sirs: This is in reply to your letter of December 5, 1983 concerning the characterization of rental and other payments made by a Canadian lessee to on Israeli lessor for the use of XXX for purposes of the Income Tax Act (Canada) (the “Act”) and the Canada-Israel Income Tax Convention (1975) (the “Convention”). ... We confirm that, in the above-noted circumstances, monthly rental payments for the use of XXX including variable amounts based on hours of use of XXX would be properly characterized as rents, royalties or similar payments' for purposes of paragraph 212(1)(d) of the Act and as royalties' for purposes of Article III of the Convention. 2. ...

Pursuant to Article 18, paragraph 1 of the Canada-France Income Tax Convention, pensions arising in France and paid in respect of past employment are taxable only in France. ... Article 18, subparagraph 2(b) of the Convention states that "pensions referred to in paragraphs 4, 5 and 6 of Article 81 of the French General Tax Code shall be exempt from Canadian tax so long as they are exempt from French tax. ... The Convention took effect, as to taxes on income, for taxation years beginning on or after January 1, 1976. ...

18 April 1990 Income Tax Severed Letter HBW 4125-C2 HBW 6591-C2 Unedited CRA Tags Canada-China Income Tax Convention article XI We are writing in regard to your letter dated January 17, 1989 (copy attached), in which you requested confirmation on the tax status of the XXX regarding, interest earned on deposits held in Canada. Our Vancouver District Office replied to the letter on April 4, 1989 (copy attached) and acknowledged tax exemption to the XXX in accordance with paragraph 3, Article 11 of the Canada-China Income Tax Convention. ... Article 3 of the Convention delegates the competent authority function to your Ministry of Finance or its authorized representative. ...

We might very well take issue on some points raised by you in the interpretation of the conventions and the relevant provisions. ... The NR4s are brought together and the appropriate ones selected from the mass for transmission under the tax convention. 3. ... When we request information under the tax convention we might also ask permission for our auditors to go to the other country to assist the person gathering the information. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI Dear Sirs: Re: Subsection 212(13.1) of the Income Tax Act and Article XI of the Canada-United States Income Tax Convention, 1980 This is in reply to your letter dated March 15, 1990 whereby you requested our views as to the application of the above-noted provisions of the Income Tax Act and the Canada-United States Income Tax Convention, 1980 (the “Treaty”) to interest paid by a partnership comprised entirely of U.S. resident individuals on a loan (not secured by real property situated in Canada or any interest therein) made by a U.S. bank to the partnership to finance the acquisition of Canadian rental property in respect of which the partners intend to make an election under section 216 of the Act. ...

4 February 1980 Income Tax Severed Letter RRRR1- Tax treatment of registered pension plan held by non-resident Unedited CRA Tags 212(1)(h), 2(3)(a), 115(1)(a)(i), Canada-Switzerland Treaty article XVIII XXX This is in reply to your letter of January 16 concerning paragraph 212(1)(h) of the Income Tax Act and Article XVIII of the Canada-Switzerland Income Tax Convention (Convention). ... We cannot agree that the opening words of Article XVIII of the Convention could have any other meaning than a payment from a Canadian source to a resident of Switzerland in the situation you have described. ...

Our comments in the September 4 memorandum apply equally to a dual resident of Canada and the U.S. or Canada and any other country where the person would be considered a resident of that other Contracting State for purposes of interpreting that particular income tax convention and that convention restricts Canada's right to tax a particular source of income. ... Income Tax Convention, Canada's right to tax such interest income would be limited to 15% and our comments in the September 4 memorandum concerning the calculation of Federal and Provincial tax apply. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI, XII, XIII Dear Sirs: Re: Withholding Tax- Partnerships This is in reply to your letter dated February 6, 1991 whereby you inquired concerning the provision of refunds of tax withheld under Part XIII of the Canadian Income Tax Act (the "Act") on interest paid to a partnership where, by virtue of the provisions of an income tax convention (such as Article XXI or Article XI of the Canada-United States Income Tax Convention, 1980), by virtue of provisions of the Act (such as subsection 212(14)) or by virtue of the fact that a partner is a resident of Canada and thus not subject to tax under Part XIII, such tax would not have been exigible or would have been exigible at a lesser rate had there not been a partnership and had the debt been owed and the interest been paid to the partners directly. ...