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Tax Convention Canada-U.S. Tax Treaty:Art. XXII Subject: XXX Application of subsection 18(4) We are writing in response to your memorandum, dated February 4, 1991, in which you requested our views on whether the Notices of Objection filed by XXX (the “taxpayer”) for 1986, 1987 and 1988 should be allowed. ... Income Tax Convention (1978) does not provide relief to the taxpayer in these circumstances. ...

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. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VIII G. Thornley (613) 995-2455 XXXX January 7, 1986 Dear Sirs: Re: Canada-U.S. Income Tax Convention (1980) (the "Treaty") This is in reply to your letter of October 29, 1985 concerning the applicable rate of withholding on annuity payments received by a U.S. resident under a matured registered retirement savings plan. ...

10 May 1990 Income Tax Severed Letter HBW 4125-S2A Unedited CRA Tags Canada-Switzerland Income Tax Convention Article XIX HBW 4125-S2 David R. Senécal (613) 957-2074 May 10, 1990 Dear xxxxx Subsequent to your letter of April 16, 1990, we have written to the Swiss tax authorities concerning their proposal to tax xxxxx despite the apparent application of Paragraph 1 of Article XIX of the Canada- Switzerland Income Tax Convention. ...

Convention the payments mentioned above would be viewed as royalty payments for the use of copyrights and are, therefore, not subject to Part XIII tax by reason of that provision of the Convention. ...

27 February 1981 Income Tax Severed Letter RCT-0540D Unedited CRA Tags 212(1)(b), Canada-France 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. ... We are providing an interim response to your inquiry concerning the Canada-France Income Tax Convention- 1976 and its application to the French islands of St.Pierre et Miquelon. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Payments for Computer Based Site Evaluation System This is in response to your memorandum of August 14th concerning the status of payment made by XXX or computer systems. ... Income Tax Convention. Turning to the question of classification or nature of the payments for the non-exclusive restricted right to use the computer system. ...

28 June 1985 Income Tax Severed Letter A-1333 Unedited CRA Tags 212(1)(b), Canada-Netherlands 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. ... Dear Sirs: Re: Canada-Netherland Income Tax Convention (the Treaty) This is in reply to your letter of March 28, 1985. ...

Income Tax Convention Art. 17 XXXX G. Thornley (613) 957-2130 May 5, 1986 Dear Sirs: Re: Withholding Tax on RRSP Withdrawals This is in reply to your letter of February 20, 1986 concerning the rate of withholding tax on RRSP withdrawals paid to residents of the United Kingdom. ... Income Tax Convention (1980) and the 1985 Protocol, lump sum RRSP withdrawals are not accorded the beneficial treatment in paragraph 1 by virtue of the words in paragraph 3 that state "but does not include any payment... in settlement of all future entitlements... ...

Tax Convention. The update agreement, as we understand, provides for normal updating of the copywritten material already dealt with under the license fee comments above. Provided the facts support this understanding then we are of the view that the payments made under the update agreement would be exempt by the operation of Article XIIIC of the tax convention in a manner similar to the license fee. ...