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Charron: Re: Canada- U.S. 1980 Tax Convention Further to our conversation of September, 27, 1984, could you kindly confirm in writing our points of discussion, as set out below: i) U.S. tax is not to be withheld where the Canadian recipient is a tax-exempt plan such as a registered pension plan or registered retirement savings plan. ii) Where the Canadian recipient is a pooled fund trust, the beneficiaries of which are tax-exempt, U.S. tax will have to be withheld as the income of the pooled fund is not "generally exempt from taxation" in Canada. iii) If U.S. tax is erroneously withheld, the Internal Revenue Service should be contacted in writing, citing the relevant paragraph of Article XXI of the above Convention, in order to recover the tax withheld. ...

Income Tax Convention (1980) We would appreciate receiving your views concerning the application of Paragraph 7 of Article XXV of the Convention in the undernoted circumstances. ...

A.Beaton RE: Articles X and XXVII Canada-United Kingdom Convention Further to your March 5, 1981 telephone conversation with Kevin Donnelly, this is to confirm that the ADM-Legislation has approved a recommendation to cancel the position set out in T.O.M. 9071 and that the Department's position will conform to the intention of the convention that the "tax credit" described in Articles XX and XXVII will be included in dividend income for Canadian tax purposes and the related 15% United Kingdom tax payable on the total of the dividend and the "tax credit" will qualify for the section 126 foreign tax credit in the year the dividend is brought into income in Canada. ...

Charlie: As promised I am enclosing two copies of the Supplementary Tax Convention with Finland: a Finnish version and a revised Canadian version. ... The underlined words are not intended to alter in any way the substance of the Finnish draft, but simply to economize on words and to conform the provision to the corresponding "in force" provision-- Article XX(3)-- of the 1959 Convention. ...

2 May 1986 Income Tax Severed Letter MAY 2-1986 XXXX Attentions XXXX Dear Sirs: Thank you for your letter of February 28 in which you enquire about the application of Interpretation Bulletin IT- 216 in the context of Articles VI and XIII of the Canada- United States Income Tax Convention and Articles 6 and 13 of the 1977 OECD Model Convention. ...

Campbell XXXX Re: Article XXI Canada-United States Income Tax Convention We have your letter of March 14, 1985, regarding the exemption on interest and dividends provided in Article XXI of the now tax convention. ...

29 August 1980 Income Tax Severed Letter August 29, 1980 LONDON DISTRICT OFFICE Informal Consultation Article 18, Paragraph 3 of the Canada-Australia Income Tax Convention (1980) With regard to the above noted, would the following situation result in non-taxable alimony receipts: Taxpayer and her husband left Canada some time ago to reside in Australia. ... It would appear from our review of the Canada-Australia Income Tax Convention, Article 18, Paragraph 3 that these receipts are non-taxable, but Hotline has advised this paragraph appears to be contradictory to the general pattern of treatment for alimony receipts where the payor resides in a country other than Canada. ...

Tax Convention. In our opinion, a Canadian resident entitled to such a tax credit would be required to recognize it in income in the same year the dividend to which it relates is received. ... Convention (New) ...

Castendyk RE: Canada-United States Income Tax Convention Article XIX- Employees of the U.S. ... Postal Service are exempt from Canadian tax under Article XIX of the new Canada-United States Income Tax Convention. ...

Donnelly Articles X and XXVII Canada-United Kingdom Convention Further to your March 5, 1981 telephone conversation with Kevin Donnelly, this is to confirm that the ADM-Legislation has approved a recommendation to cancel the position set out in T.O.M. 9071 and that the Department's position will conform to the intention of the convention that the "tax credit" described in Articles X and XXVII will be included in dividend income for Canadian tax purposes and the related 15% United Kingdom tax payable on the total of the dividend and the "tax credit" will qualify for the section 126 foreign tax credit in the year the dividend is brought into income in Canada. ...