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Miscellaneous severed letter

14 June 1989 Income Tax Severed Letter 7850 - 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

23 June 1988 Income Tax Severed Letter

Tax Convention. Does this mean that since the cost of an annuity or R.R.I.F. was deductible from the income of the registered owner through contributions to a R.R.S. ... Tax Convention, it would seem that the R.R.I.F. payments would qualify as annuities under the definition of the term "annuities" in paragraph 4 of Article XVII. ...
Miscellaneous severed letter

10 January 1979 Income Tax Severed Letter

Income Tax Convention (1978) Thank you for your memorandum of December 27 in which you relate the Department of Finance's suggestion on how we could interpret Article XVII 1 of the above-mentioned Convention in order to tax the lump sum payments from a Canadian pension plan to a United Kingdom pension plan. ...
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)(i) 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

14 December 1978 Income Tax Severed Letter

Income Tax Convention (1978) We expressed the position in the attached letter of October 17 that the lump sum payment from a Canadian pension plan to a United Kingdom pension plan will be subject to Canadian tax on the amount in excess of the limits set out in section 1 of Article XVII of the above-mentioned Convention which has yet to be ratified. ...
Miscellaneous severed letter

3 June 1983 Income Tax Severed Letter

Tax Convention (1978) Further to your recent discussions with Ms. C. Muirhead of this Department, attached for your files are copies of correspondence concerning the subject matter. ... Tax Convention (1978) ...
Miscellaneous severed letter

7 October 1974 Income Tax Severed Letter

7 October 1974 Income Tax Severed Letter XXXX CPP/UI/NRT 2nd Floor 266--8731 October 7, 1974 Dear Sirs: Re: The Canada-Australia Tax Convention Article XII The Calgary Alberta area has in the past had many of its' teachers leave for a teaching assignment in Australia with the anticipation of remaining in Australia for a period of 24 months or less. They were under the assumption by virtue of the Canada-Australia Tax Convention Article XII that they would not pay tax in Australia if the conditions of the Article were met. ...
Miscellaneous severed letter

20 May 1986 Income Tax Severed Letter 5-1282 - [860520]

We have read the material submitted with your letters and it is our view that these congresses represent conventions for the purpose of subsection 20(10) of the Income Tax Act. However, the extent to which an individual is entitled to deduct expenses incurred in attending a convention is determinable only after that individual's return is filed and all relevant facts are disclosed. ...
Miscellaneous severed letter

31 January 1984 Income Tax Severed Letter A17082 - [840131]

Tax Convention is a question of fact. If the bareboat charter fees charged to XXXX are similar to those which would be charged to an independent enterprise then Article IV of the Canada-U.S. Tax Convention will not apply. That determination is not an area dealt with by this Directorate. ...
Miscellaneous severed letter

6 February 1991 Income Tax Severed Letter

Senécal of this division, we are of the view that there is no provision in Canada-Korea Income Tax Convention which would prevent Korea from taxing a royalty payment to a resident of Canada solely on the fact that the fee was paid in the form of a lump sum amount rather than a series of periodic payments. We also confirm that the Convention does not provide an exemption for payments of license fees involving "new advanced technology". ...

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