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Tax Convention (the "Convention") and the Court was of the view that the definition in the Convention was not broad enough to include a payment for the use of computer software in perpetuity even though such amounts fall within paragraph 212(1)(d) of the Act. ...

23 January 1984 Income Tax Severed Letter 9A-9141 F 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. ...

4 February 1980 Income Tax Severed Letter 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. ...

Income Tax Convention. As we see it, Article VII of the Convention operates to preclude Canadian taxation of any profits other than profits attributable to a Canadian permanent establishment. ... Therefore, since the interest income constitutes "profit" of the U.K. subsidiary and is not attributable to a Canadian permanent establishment, then the Convention should apply to prevent Canadian withholding tax from being applied to the interest payments. ...

Campbell LI 1420-1 Social Security Payments under the new Canada-United States Income Tax Convention We have received an inquiry from Health and Welfare with respect to the effect of the Tax Convention on the guaranteed income supplement. ... Original Signed by Director Provincial and International Relations Division EEC/jb O.P.R.U Article XVIII- Canada-United States Income Tax Convention ...

Income Tax Convention (1978) Recently I was discussing a particular aspect of the convention with our international tax partner, XXXX in our Montreal office. ... I would hesitate to do so in any event but more particularly because of the inclusion of the word "indirectly" in Article XIII of the Canada-UK Tax Convention. ...

Harding This is in reply to your letter of July 22, 1983 concerning Article IV of the Canada-United Kingdom Income Tax Convention. ... Generally speaking, a "permanent home", for purposes of the Convention, is one which must be permanent and the individual must have arranged and retained it for his permanent use as opposed to staying at a particular place under conditions that his stay is intended to be of short duration. ... Article IV- Canada-United Kingdom Tax Convention Article IV- OECD ...

Harding Dear Sirs: This is in reply to your letter of February 26, 1985, concerning paragraph 7 of Article XXV of the Canada-United States Income Tax Convention. ... It is our view that paragraph 7 of Article XXV of the Convention does not override section 19 of the Act since the deduction provided in paragraph 7 is based on a payment being deductible as if it were paid to a resident of Canada. ... Accordingly, we are of the view that the wording of paragraph 7 does not permit us to grant a deduction for the above expenses nor was it the intention of the negotiators to permit the Convention to override the provisions of sections 19 and 19.1 of the Act. ...

McColm (613) 995-2455 January 23, 1984 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 an Israeli lessor for the use of XXXX 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 XXXX including variable amounts based on hours of use of XXXX would be properly characterized as 'rents, royalties or similar payments' for purposes of paragraph 212(1)(2) of the Act and as 'royalties' for purposes of Article XIII of the Convention. 2. ...

Ken Major, Chief, Foreign Section FROM- Head Office International Audits Division André Lamarche (613) 957-8859 SUBJECT: Paragraph 3 and 4 of article XIII of the Canada- U.S Income Tax Convention (1980) Recently, we have received a few referrals from District Offices concerning the definition of real property as referred to in paragraph 3 of article XIII of the Canada- U.S. Income Tax Convention. Basically, paragraphs 3 and 4 state that a disposition of real property by a non-resident will be taxed in the country in which the property is located. ... What was the purpose of article XIII paragraph 3 of the Canada- U.S. tax convention? ...