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Double Taxation Conventions 5. 1. Do you consider the payments and receipts referred to in 2.1 and 3.1 come under Article 12 of the Model Convention? ... 5. 4 Do you generally adopt Article 12 of the Model Convention in your tax treaties with other Member countries? ... Double taxation Convention 5. 1. See discussion under 2.1.1. and 3.1.1. 5. 2. ...

Convention or are to be taxed as royalties in accordance with Articles II and XI of the Convention and Article 6(a) of the Protocol. ... Convention and the word 'royalties' in paragraph 212(1)(d) of the Income tax Act. ... The question is whether such payments are 'royalties' for the purposes of the Convention to gains from the sale or exchange of capital assets within Article VIII of the Convention. ...

Convention or are to be taxed as royalties in accordance with Articles II and XI of the Convention and Article 6(a) of the Protocol. ... Convention and the word 'royalties' in paragraph 212(1)(d) of the Income tax Act. ... The question is whether such payments are 'royalties' for the purposes of the Convention to gains from the sale or exchange of capital assets within Article VIII of the Convention. ...

OPINION REQUESTED: Does the term "interest" as defined under Article 11 of the Canada-Australia Income Tax Convention (1980) include interest on funds on deposit at a Canadian chartered bank? ... S earns on these funds then be subject to a non-resident withholding tax not exceeding 15% according to Article 11 of the Canada-Australia Income Tax Convention (1980)? ...

The Associates Corporation of North America [[1980] C.T.C. 80] (80 DTC 6049) case has been accepted by the Department as a precedent for the purposes of the Canada-United States Tax Convention only i.e. guarantee fees are not interest for purposes of the Canada-United States Tax Convention. ...

" Unless the statutory withholding rate is reduced by virtue of an International Tax Convention, any person making such a payment is required, by law, to withhold at the 25% rate. Since the Tax Convention between Canada and South Africa was terminated on September 23, 1985, there is no provision that would permit withholding at a lower rate in any circumstance. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI Dear Sirs: This is in response to your letter of May 2, 1988. ... Income Tax Convention (1980) and the Act to apply a withholding tax at a rate of 15% to interest income earned in Canada by a resident of the United States. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII This is in reply to your memorandum dated June 19, 1989, in which you asked for the criteria to be used in determining in which country a pension or annuity "arises". ... Income Tax Convention (1980), pension and annuity income arises in the state from which it is paid. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII XXX This is in reply to your letter of March 21, 1988 and to our telephone conversation of May 12 concerning the tax treatment of Canada Pension Plan (CPP) benefits and a pension you are receiving from the XXX. ... Income Tax Convention. It is our view that benefits paid from the CPP would fall within the social security legislation of Canada, however, you may wish to confirm this interpretation with the Internal Revenue Service. ...

19 November 1987 Income Tax Severed Letter RRR4 Unedited CRA Tags 212(1)(d), Canada-Norway Income Tax Convention 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. ... RE: Information Circular 76-12R3 Footnote (6) Canada-Norway Income Tax Convention As discussed with you in a recent telephone conversation, we suggest that you consider amending Information Circular 76-12R3 to clarify the Department's position on the rate of withholding tax that applies to rental income from moveable property received by a resident of Norway from a resident of Canada. ...