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Income Tax Convention] DATE JUN 2 1988. Audit Directorate International Audits Division Reorganizations and Non-Resident Division Foreign Section N.R. ... Income Tax Convention (the "Convention") This is in reply to your memorandum of March 10, 1988. At issue are the following words in paragraph 5 of Article XXV of the Convention: "...the capital of which is wholly or partly owned or controlled... ...

Income Tax Convention (1980)] DATE: February 20, 1986 TO-A DATE: PROVINCIAL AND INTERNATIONAL RELATIONS DIVISION FROM-DE HEAD OFFICE Assessing Division ATTENTION R. ... Income Tax Convention (1980) We are writing to request clarification of Article XIX of the Canada-United States Income Tax Convention (1980) as it applies to employees of the U.S. ... Article XIX of the 1980 Convention no longer includes a reference to "any agency" of the United States. ...

Income Tax Convention- Exemption Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Income Tax Convention ("Convention") Enclosed, for your information and use, are copies of our recent correspondence with 19(1) of the legal firm 24(1) in Montreal concerning 19(1) claim for an exemption from Canadian income tax under the Convention. ...

7 July 1990 Income Tax Severed Letter- Deductibility of expenses relating to a convention to be held aboard a cruise ship Unedited CRA Tags 20(10) Dear Sirs: This is in reply to your letter of May 23, 1990, concerning the deductibility of expenses relating to a convention to be held aboard a cruise ship. The Department's position as set out in paragraph 2 of Interpretation Bulletin IT-131R2 is that a convention held during an ocean cruise is considered as being held outside the territorial scope of the organization. Since subsection 20(10) of the Income Tax Act requires the convention to be held at a location that can reasonably be regarded as consistent with the territorial scope of the organization it is our view that the expenses relating to a convention that your clients propose to hold during an ocean cruise (a cruise to Alaska is considered an ocean cruise) would not be deductible by the members. ...

24 July 1990 Income Tax Severed Letter ACC9404- Deductibility of Convention Expenses 24(1) 900982 W.P. Guglich (613) 957-2102 Attention: 19(1) JUL 24 1990 Dear Sirs: This is in reply to your letter of May 23, 1990, concerning the deductibility of expenses relating to a convention to be held aboard a cruise ship. ... Since subsection 20(10) of the Income Tax Act requires the convention to be held at a location that can reasonably be regarded as consistent with the territorial scope of the organization it is our view that the expenses relating to a convention that your clients propose to hold during an ocean cruise (a cruise to Alaska is considered an ocean cruise) would not be deductible by the members. ...

7 December 1990 Income Tax Severed Letter- Canada-Netherlands Income Tax Convention Unedited CRA Tags Canada–Netherlands Income Tax Convention, Art. 3, 4, OECD Model Double Taxation Convention of 1977 Dear Mr. ... In our view, the wording of paragraph 3 of Article 4 of the Canada- Netherlands Income Tax Convention has the same effect. ... Where agreement cannot be reached, the corporation will not be a resident of either State for most purposes of the Convention. ...

19 May 1987 Income Tax Severed Letter 5-3225- [Article XVII of the Canada-UK Tax Convention] XXXX D. ... With regard to 1985, paragraph 1 of Article XVII of the Canada-United Kingdom Tax Convention (1978) (the "Convention") as it read before its amendment on April 6, 1986 permits the United Kingdom to tax Canadian-sourced pensions received by a resident of the United Kingdom. ... As you are aware, Article XVII of the Convention was amended effective April 6, 1986. ...

Tax Convention (1978) (the "Convention"). An individual (the "taxpayer"), formerly resident in Canada owned real estate property (the "real property") located in the United Kingdom (the "UK"). ... Canada), in accordance with the Convention". By virtue of paragraphs 2(a) and 3, this gain is deemed to arise from sources within Canada. ... This type of problem may have to be resolved through the competent authority procedures set out in Article XXIII of the Convention. ...

22 May 1990 Income Tax Severed Letter RRRR257- Taxation of foreign embassy employees — Canada-Netherlands Income Tax Convention Unedited CRA Tags Canada-Netherlands Income Tax Convention Your file Votre référence Our file Notre référence 5-9771 W.C. ... Before we address your first query, we must first clarify the Department's position on the taxation of foreign embassy employees under the provisions of the Income Tax Act (the "Act") and the Canada- Netherlands Income Tax Convention (1986) the ("Convention"). ... In this latter case, Canada will provide a tax credit as required by Articles 22(4) and 22(5)(a) of the convention for any Netherlands' taxes paid. ...

Income Tax Convention on Capital Gains Revenue Canada Revenu Canada Taxation lmpôt Head Office Bureau principal 5-9618 S. ... Tax Convention (1978) (the "Convention"). An individual (the "taxpayer"), formerly resident in Canada owned real estate property (the "real property") located in the United Kingdom (the "UK"). ... This type of problem may have to be resolved through the competent authority procedures set out in Article VIII of the Convention. ...