Search - convention

Donnelly Re: Article 27(2)- Canada-United Kingdom Convention We would appreciate your assistance in identifying situations covered by Article 27(2) of the Canada-United Kingdom Convention. ...

10 February 1976 Income Tax Severed Letter Source Deductions Division Non-Resident Tax Section February 10, 1976 Dear Sirs: Re: Canada- Norway Tax Convention Canada- Netherlands Tax Agreement This is in reply to your letter dated December 15, 1975. ... Therefore, any payments made by such Canadian resident trusts would be governed by Article 12 of the Convention when paid to beneficiaries of Norway and subject to a withholding tax rate of 15% pursuant to Article 12(2). ...

Pinkus Director RE: Article XXI of the Canada-US Income Tax Convention (1980) Attached, as requested, are publications that you may pass to the I.R.S. which should help them to determine, in relation to article XXI of the Canada-US Convention (1980) the type of organization which qualifies for registration as a charity under paragraph 110(8)(c) of the Income Tax Act. ...

TAXATION AUTHORITIES ON RESIDENTS OF WEST GERMANY Issue XXXX Response THE HONOURABLE MEMBERS SHOULD KNOW THAT INCOME TAX CONVENTIONS WITH MANY COUNTRIES PROVIDE FOR AN EXCHANGE OF INFORMATION TO FACILITATE ADMINISTRATION OF THE DOMESTIC LAWS OF THE CONTRACTING STATES. ... Most modern tax conventions provide for an exchange of such information, usually upon request. ...

Donnelly (613) 995-0038 XXXX Dear Sirs: This is in reply to your letter dated December 8, 1901 requesting our views on the meaning of the words "not borne by" in subparagraph 2(c) of Article XV of the Canada-United Kingdom Tax Convention (1978). ... " Similar wording is to be found in Article XII of the Canada-Netherlands Tax Convention, i.e., "shall not have been charged. ...

Income Tax Convention, such payments were not taxable by Canada. However, under the recently ratified Canada-U.S. Income Tax Convention (1980), such payments will be taxable by Canada as of January 1, 1986 at a rate of 15%. ...

The present Canada-Denmark Income Tax Convention clearly does not prevent the banish authorities from taxing such pensions. The latest draft on file of the proposed Convention would eliminate this problem in the future since such pensions are taxable in the State in which they arise. ...

Donnelly Re: Article 27(2)- Canada-United Kingdom Convention We would appreciate your assistance in identifying situations covered by Article 27(2) of the Canada-United Kingdom Convention. ...

Tax Convention Further to our telephone conversation of September 14, 1984, we would like you to give us an interpretation of sourcing with respect to articles X, XI and XXIV of the Convention. ...

Re: Article XXI(2), Canada-United States Income Tax Convention This is in reply to your letter of October 3, 1984 concerning the above captioned matter. You indicate that in your view Article XXI(2) of the new Convention will not exempt from United States withholding tax dividends and interest received from United States sources by a mutual fund trust as defined in subsection 132(6) of the Income Tax Act. ...