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Results 871 - 880 of 1551 for convention
Miscellaneous severed letter
13 December 1989 Income Tax Severed Letter RCT-0500A
In the meantime we suggest that you proceed with the preparation of a formal request for information under the provisions of the Canada-Netherlands tax convention. ... Although TOM11(11)7.2 specifically deals with exchanges under the Canada-United States convention through Special Investigations, the instructions as to the content of the request have equal application to requests being sent to other treaty partners. ...
Miscellaneous severed letter
9 November 1981 Income Tax Severed Letter RCT-0501C
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. ... Income Tax Convention. Turning to the question of classification or nature of the payments for the non-exclusive restricted right to use the computer system. ...
Miscellaneous severed letter
29 April 1982 Income Tax Severed Letter A-6558
Tax Convention is not applicable, since that Article exempts only payments of a periodic nature. Also, by virtue of Article XI of that Convention, the rate of withholding tax is limited to 15%. ...
Miscellaneous severed letter
5 July 1984 Income Tax Severed Letter 9A-0043 F
Convention which is currently in force or the exemption contained in subparagraph 212(1)(d)(vi) of the Act to such payments paid or credited the non-resident person. ... Convention will operate to exempt from tax awards of damages or payments pursuant to out of court settlements made in connection with the wrongful misappropriation of copyrights, since both provisions refer to payments made pursuant to the terms of consensual agreements. ...
Miscellaneous severed letter
6 February 1985 Income Tax Severed Letter 9A-0848 F
Income Tax Convention (1980) (and Article XIIIC of the previous convention), it is our view that a royalty paid for the use of a videotape of a motion picture film is a "royalty in respect of a motion picture film". ...
Miscellaneous severed letter
14 June 1989 Income Tax Severed Letter 89M06083 F - Business Meeting Expenses
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. ...
Miscellaneous severed letter
17 September 1987 Income Tax Severed Letter 95-3724 F
It is our opinion that reasonable management fees paid to a person resident in the United States will fall within Article VII or Article XIV of the Canada-U.S. 1980 Tax Convention and reasonable management fees paid to a resident of the United Kingdom will fall within Article 7 or Article 14 of the Canada-U.K. Convention. Accordingly, such fees would only be taxable in Canada if the United States or United Kingdom resident, as the case may be, carries on business In Canada through a permanent establishment or fixed base situated in Canada, and only to the extent the fees are attributable thereto. ...
Miscellaneous severed letter
11 August 1983 Income Tax Severed Letter 9B-4571 F
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. ...
Miscellaneous severed letter
29 April 1982 Income Tax Severed Letter 9A-6558 F
Tax Convention is not applicable, since that Article exempts only payments of a periodic nature. Also, by virtue of Article XI of that Convention, the rate of withholding tax is limited to 15%. ...
Miscellaneous severed letter
20 February 1985 Income Tax Severed Letter 9A-0973 F
Income Tax Convention (the "Treaty"), although the Treaty reduces the rate of tax to 10%. ... Income Tax Convention, use payments for television programs originally recorded on videotape are exempt from withholding tax. ...