Search - convention
Results 881 - 890 of 1551 for convention
Miscellaneous severed letter
13 December 1989 Income Tax Severed Letter ACC8857 F - Request for Information from The Netherlands
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 TOM 11(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
4 March 1988 Income Tax Severed Letter NR0022 - []
Tax Convention Taxation of OAP/CPP/QPP Benefits Further- to your telephone conversation with Eric Hammond of this section, would you please provide us with your opinion as to what extent, if any, the Canada-U.S. Tax Convention (1980) will have, when a U.S. non-resident individual makes an election under Section 217 of the Act. ...
Miscellaneous severed letter
3 December 1987 Income Tax Severed Letter
Paragraph 4 of Article XXIV of the Convention does not preclude Canada from applying subsection 20(11) of the Income Tax Act and therefore the non-business income tax, as defined in paragraph 126(7)(c), is automatically reduced by the amount deducted under subsection 20(11) of the Act. ... Accordingly, XXXX should be permitted a foreign tax credit under subsection 129(1) of the Act in respect to the amount determined under paragraph 126(7)(c) of the Act after making the appropriate deduction under subsection 20(11) of the Act, Since this is in accordance with the provisions of Article XVIII and XXIV of the Convention, the U.S. will treat a portion of the pension income as arising in Canada in order to avoid double taxation as provided for in paragraph 6 of the latter Article. ...
Miscellaneous severed letter
10 March 1988 Income Tax Severed Letter
Income Tax Convention- Article XXV(5) In reviewing a training course on the above Convention for CCD, an interpretation problem has arisen in respect of Article XXV(5) for which we wish to ask your opinion. ...
Miscellaneous severed letter
29 April 1981 Income Tax Severed Letter
Superannuation or pension benefits received by a Canadian resident from a foreign source are taxable under subparagraph 56(1)(a)(1) of the Income Tax Act unless exempted by a tax convention. The Canada/U.S. tax convention in force does not provide this exemption and therefore subparagraph 56(1)(a)(i) would be applicable in the above situation. ...
Miscellaneous severed letter
1 June 1981 Income Tax Severed Letter
Harding Thank you for your letter of May 20th, 1981 responding to my inquiry concerning Paragraph 7 of Article X of the proposed Canada-United States Income Tax Convention (Convention). ...
Miscellaneous severed letter
15 October 1981 Income Tax Severed Letter
Companies Article X, Canada-United-Kingdom Income Tax Convention This is in reply to your letter dated October 2, 1981 concerning the above. ... We confirm that Canadian returns for past years reporting only net U.K. dividends will be allowed to stand, unless the tax- payer specifically requests a reassessment as provided for under Article XXVIII of the Convention. ...
Miscellaneous severed letter
2 October 1984 Income Tax Severed Letter
It is our understanding that the wording in paragraph 2 of Article XXI of the Canada-United States Income Tax Convention, 1980 (Convention) was amended because it was not broad enough to cover unit trusts of life insurance companies investing funds on behalf of pension plans. ...
Miscellaneous severed letter
4 February 1977 Income Tax Severed Letter
Lanos Canada-Ireland Income Tax Convention Article IX In an adverse decision of the Tax Review Board dated November 25, 1976 (Patrick J. ... Byrne was "ordinarily resident in Canada" only because of his employment (as a director of the Irish Development Authority, a non-profit branch of the Department of Industry and Commerce in Ireland) and as such came clearly within the provisions of Article IX of the above Convention.. ...
Miscellaneous severed letter
16 December 1985 Income Tax Severed Letter
We have reviewed the procedures of this Department concerning the exchange of information between Canada and the United States pursuant to Article XXVII of the Canada-United States Income Tax Convention. ... You also questioned whether it was possible for information relating to addresses not covered by the Canada-United States Income Tax Convention could have inadvertently been sent to the U.S. government. ...