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Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Canada-U.S. Income Tax Convention ("U.S. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII, XIIIC Issue: Whether payments to a U.S. resident for a live telecast of a sporting event are subject to Part XIII tax and, if so, is the rate of withholding tax reduced or eliminated pursuant to either Canada-U.S. income Tax Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Dear Sirs: This is in reply to your letter of July 10, 1989. You have requested clarification of the Department's basis for the position it took in its response to question no. 41 at the 1988 Revenue Canada Round Table, Specifically, in your view when a licence agreement gives a Canadian end-user of Computer software the right to make copies for internal use, the payment under the licence agreement, made to a resident of the United States, should qualify for an exemption from Canadian withholding tax under subparagraph 212(1)(d)(vi) of the Income Tax Act (the "Act") and paragraph 3 o.f Article XII of the Canada-U.S, Income Tax Convention (1980) (the "Treaty"). ...

Tax Convention Canada-U.S. Tax Treaty:Art. IV Please find attached a letter from XXX requesting our opinion on the residence of the above-noted trust. ... Income Tax Convention (1980), a trust resident in Canada with income beneficiaries in the U.S may have dual residence. ...

XXX We should, however, point out that the terms of any tax convention between Canada and the country of which the non-resident is a resident would have to be reviewed to determine whether the convention would override the provisions of the Act. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VIA XXX This is in reply to your letter of March 3 concerning Canadian withholding tax on annuity payments from a deferred profit sharing plan (DPSP). ... Tax Convention. As requested, we confirm that an exemption from Canadian withholding tax would be available to the recipient of a lump sum payment from a DPSP if he were to roll the payment into an RRSP while resident in Canada and were to receive annuity payments pursuant to the terms of the RRSP upon maturity while a resident of the United States. ...

DEPARTMENT'S POSITION A distinction must be made between: (1) expenses of attending business meetings and (2) expenses incurred in attending conventions. ... The Department's position with respect to costs incurred in attending a convention is set out in Interpretation Bulletin IT-131R. ...

Income Tax Convention Art. 13(7)(b) Dear Sirs: Re: Article 13 of the Canada-United Kingdom Income Tax Convention (the “Treaty”) This is in reply to your letter dated August 31, 1989 whereby you requested our opinion concerning the application of paragraph 7(b) of the Article 13 of the Treaty to a mine and a mill. ...

7 December 1990 Income Tax Severed Letter- Canada-Netherlands Social Security Agreement Unedited CRA Tags Canada–Netherlands Income Tax Convention Dear XXX We are writing further to your letter of December 3, 1990, concerning the application of the coverage provisions of the Agreement on Social Security between Canada and the Netherlands. ... Response: With respect to taxation issues, the provisions of the Canada-Netherlands Income Tax Convention would apply and in this regard we have attached a copy of Article XII, which deals with remuneration for services. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Convention this is in reply to your Round Trip Memorandum of May 30 concerning payments made to XXX, a U.S. resident corporation which presumably has no permanent establishment in Canada, for the right to use recorded material. ...