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Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère. 5-932359 XXXXXXXXXX Carole Chouinard (613) 957-8953 A l'attention de XXXXXXXXXX Le 29 octobre 1993 Mesdames, Messieurs, Objet: Convention signée par des conjoints de fait La présente fait suite à votre lettre du 9 août 1993 dans laquelle vous demandez notre opinion concernant la recevabilité d'une convention signée par des conjoints de fait pour les fins de la Loi de l'impôt sur le revenu (ci-après la «Loi»). ...

Subsection 20(10) of the Income Tax Act specifically permits a deduction in respect of expenses incurred in attending not more than two conventions per year for taxpayers who are carrying on a business. ... Concerning the amounts paid to attend this convention which may be deductible from professional income, we have attached a copy of Interpretation Bulletin IT-518 and would direct your attention to paragraph 4. ...

" Unless the statutory withholding rate is reduced by virtue of an International Tax Convention, any person making such a payment is required, by law, to withhold at the 25% rate. Since the Tax Convention between Canada and South Africa was terminated on September 23, 1985, there is no provision that would permit withholding at at a lower rate in any circumstance. ...

Tax Convention March 22, 1990 Mr. K.H. Major Provincial and International Chief Relations Division Foreign Section E.E. Campbell Specialty Rulings Division Permanent Establishments- Offshore Rigs You wrote to us concerning the application of the Canada-United States Income Tax Convention and the determination of permanent establishments using the concept that space was available in certain circumstances. ...

Tax Convention are applicable. The U.S. resident supplier is therefore taxable only to the extent that profits from the sale of the tapes are attributable to a permanent establishment in Canada. Under the proposed Canada-U.S. convention, such payments would appear to be subject to a 10% rate of tax. ...

21 September 1989 Income Tax Severed Letter HBW 4125-N1 Unedited CRA Tags 56(1)(a), 110(1)(f)(i), 126(1)(b)(ii)(A)(III), Canada-Netherlands Income Tax Convention Dear XXX: We are writing in reply to your letter of August 17, 1989, concerning the Canada-Netherlands Income Tax Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII We are writing in reply to your letter dated March 21, 1990, concerning the tax treatment of Canadian Government Annuities. ... Paragraph 2(b), Article 18 of the Canada-United States Income Tax Convention reduces this withholding tax to 15%. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Dear Sirs: This is further to your telephone conversation with the writer on April 5 concerning payments to U.S. residents for the use of videotaped TV programs and computer software programs. ... Income Tax Convention, notwithstanding our previous opinion to the contrary given to you on October 14, 1981. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XXI We are writing in reply to your letter dated February 21, 1990, concerning tax exemption for XXX. Artic1e XXI of the Canada-United States Income Tax convention does not apply as the XXX is not a resident of either contracting state. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIIIC Dear Sirs: This is in reply to your letter of March 18 concerning Article XIIIC of the Canada-U.S. Income Tax Convention (1942). We agree that the provisions of the said Article XIIIC exempt from tax, otherwise imposed by subsection 212(5) of the Income Tax Act, payments made for the right in or to the use of a videotape for use in connection with television broadcasting. ...