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Tax Convention (1978) override those of Article VII in the said treaty. ... However, Article XXVIII(4) provides that if greater relief was afforded by any provision of the earlier treaty, such provision 'shall continue to have effect in Canada for any taxation year beginning before the entry into force of this Convention'. ... Convention Articles VII, XVI(2), XXVIII(4) ...

Convention (1980) We would appreciate your views on the following matters. Paragraph 1 of Article XVIII of the Convention provides that the amount of a pension arising in a Contracting State and paid to a resident of the other Contracting State shall be exempt from taxation in that other State to the extent that it would be excluded from taxable income in the first mentioned State if the recipient were a resident thereof. ... In this context, we note that pursuant to the provisions of paragraph 5 of Article XXIX of the Convention, the timing of the U.S. taxation of the growth in an RRSP may be deferred until receipt if the taxpayer so elects. ...

XXXX Article XVII of the Canada-United Kingdom Tax Convention (1978) titled Pensions and Annuities, a copy of which is attached for your perusal, provides that pensions paid out of the public funds of the United Kingdom to an individual in respect of services rendered to that Government may be taxed in the United Kingdom. ... Since the United Kingdom Government has retained the right to tax certain government pensions under the terms of the Canada-United Kingdom Tax Convention, Canadian residents are required to provide the United Kingdom authorities with whatever information they require if they wish to obtain the reduced rate of withholding on their pension income. It should also be noted that the United Kingdom has the authority to verify such information provided by the Canadian resident with the Canadian authorities pursuant to Article XXIV of the Canada-United Kingdom Tax Convention (copy attached). ...

Tax Convention (1978) I agree that the subject Article can be interpreted in a manner such that the $10,000 exemption figure would include CPP and OAS payments, since these payments are without doubt "pensions". However, it is my view that exempting articles of a convention should be considered to apply to amounts that are otherwise taxable; i.e., one looks to a convention as a last resort. ...

Section 116 of the Act gives no leeway when the property sold by the non-resident might be eligible for the principal residence exemption, the capital gains exemption or an exemption under a tax convention. ... Paragraph 24 of the Circular states that the Department allows sellers to apply for an exemption under a particular tax convention at the time they file a notice of disposition. The sellers must then refer to the applicable section or paragraph of the particular convention between Canada and their country of residence. ...

However, the Convention limited the withholding tax in Canada to 25 percent of the excess of all pension and annuity income in excess of the greater of $10,000 Canadian or £5,000 sterling. ... A Second Protocol to the Convention was ratified on December 23, 1985 and made a basic change to the treatment of pension income. ... We are enclosing a copy of the Protocol to the Convention for your perusal. ...

He also states that since the present Canada-United Kingdom Income Tax Convention entered into force, he is taxed in both countries on his world income. Pursuant to Article XVII of the Canada-United Kingdom Income Tax Convention, the United Kingdom maintains the right to tax public pensions. ... The Canadian Income Tax Act and the Canada-United Kingdom Income Tax Convention provides for a deduction from Canadian taxes in respect of income taxes paid to a country other than Canada. ...

We might very well take issue on some points raised by you in the interpretation of the conventions and the relevant provisions. ... The NR4s are brought together and the appropriate ones selected form the mass for transmission under the tax convention. 3. ... When we request information under the tax convention we might also ask permission for our auditors to go to the other country to assist the person gathering the information. ...

Notamment, la convention être Holdco et l'employé cadre prévoit l'obligation (et le droit) d'acheter les actions d'Opco détenues par l'employé à leur juste valeur marchande à la cessation d'emploi et les références à des actions catégorie B doivent être lues comme étant des références a des actions ordinaires. ... Enfin pour ce qui est de la question à savoir si l 6205(4)(d) du règlement s'applique nonobstant le fait que les actions peuvent être rachetées contrairement aux dispositions des divisions 6205(1)a)(i) (D) et (G), nous confirmons que la présence d'une convention écrite entre les actionnaires d'une corporation privée détenant plus de 50% de ses actions avec plein droit de vote, a pour effet de surseoir aux exigences desdites divisions pourvu que la convention n'ait pas été conclue pour éviter ou limiter l'application des paragraphes 110.6(8) ou (9) de la Loi. ...

Income Tax Convention (1980) would be applicable to such payments rather than the Canada-France Tax Convention. ... Income Tax Convention. We trust these comments are suitable for your purposes and we will forward a copy of our reply to the Toronto District Taxation Office for their information. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch c.c. ...