Search - convention

8 April 1981 Income Tax Severed Letter RCT-0147 Unedited CRA Tags 212(1)(h), Canada-Netherlands Income Tax Convention article XVII 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. ... We confirm that the above transfer can be made without Canadian withholding tax being levied at source because of Article XVII of the Canada-Netherlands Income Tax Convention providing, of course, that the recipient of the funds is considered to be a resident of the Netherlands. ...

Our position has been that we cannot provide information which is related solely to years covered by th 1942 Convention, because it does not cover the collections area. If there are years covered by the 1980 Convention we shall cooperate to the best of or ability in obtaining the information. ...

Short General Director of Legislation Department of Finance Tax Policy and Legislation Branch L'Esplanade Laurier 140 O'Connor Street Ottawa, Ontario K1A 0G5 RE: FOREIGN GIFTS BY A CANADIAN RESIDENT Dear Sir, We refer you to paragraph XXI(6) of the Canada-U.S Tax Convention which contemplates the deductibility of gifts made directly by Canadian residents to qualifying foreign charities. In view of the recently proposed changes to the Income Tax Act which would qualify eligible domestic gifts made in the 1988 or subsequent taxation years for charitable donation "tax credit" treatment, would you kindly advise us to how these changes affect paragraph XXI(6) of the said Convention. ...

Tax Convention (1980). We confirm that paragraph 2(a), as presently agreed to, will have application to reduce the rate of withholding tax to 10% on dividends subject to tax pursuant to subsections 219(5.3) and 212(2). ... Convention ...

Tax Convention (1980) INDEXED We are enclosing a letter from Mr. XXXX, dated May 20 for your attention since he seems to be asking if a trust not governed by a registered pension fund or plan can be exempt under paragraph 149(1)(o) of the Income Tax Act as a means of raising what he perceives to be a deficiency in the above Convention. ...

Nancy Kelly REW 4109-U3 Tax Convention (1980) Canada- United States Article XIX In answer to you enquiry of February 20, 1986 and further to our recent telephone conversation, we confirm that the duties of the employees of the United States Postal Service are considered to be functions of a governmental nature for the purposes of Article XIX of the Canada- United States Income Tax Convention. ...

Arsenault (613) 957-2126 June 13 1991 Dear Sir: Re: Canada-Israel Income Tax Convention, 1975 Alimony: Article XVIII(3)(c) This is in reply to your letter dated April 17, 1991. We concur with your view that subparagraph 3(c) of Article XVIII of the Canada-Israel Income Tax Convention, 1975 will not exempt alimony paid by a resident of Canada to a resident of Israel from Canadian tax under paragraph 212(1)(f) of the Canadian Income Tax Act if the alimony payments are not taken into account in determining the income of the resident of Israel for Israeli income tax purposes. ...

Income Tax Convention reduces the rate of withholding tax on dividends if the beneficial owner of the dividends is a company which owns it beast 10% of the voting stock of the company paying the dividends. ... Income Tax Convention, it is the Department's opinion that the 10% test is determined by reference to the number of issued and outstanding shares of the company which entitle the holder to a vote. ...

Income Tax Convention (the "Convention"). If such company's mind and management is in Canada, it will only be resident of Canada for the purposes of paragraph 1 of Article 4 of the Convention, paragraph 3 of Article 4 of the Convention will not apply and subsection 250(5) of the Act will not apply. ...

Income Tax Convention (the "Convention") does not adequately deal with private retirement plans and that the term "periodic pension payment", as used in Article XVIII of the Convention should be clarified since both countries are treating the term differently. XXXX has specifically set out the following problems which need to be addressed and he has suggested an amendment to the Convention to resolve such problems. 1. ...