Search - convention

Income Tax Convention (Convention). You are concerned whether the withholding tax paid on the imputed interest qualifies as a "non-business income tax" of the Canadian parent and to which year the tax relates, (i.e. the year the withholding tax arises or the year in which the interest is accrued). It is our view that the definition of the word "interest" as defined in paragraph 4 of Article XI of the Convention is broad enough to cover amounts which are considered as interest under U.S. domestic law. ... Furthermore, we are in agreement that the withholding tax paid by the subsidiary on interest it accrues would qualify as a tax paid pursuant to paragraph 2(b) of Article II (Taxes Covered) of the Convention since the tax on the imputed interest is a tax imposed under the Internal Revenue Code. ...

Arsenault (613) 957-2126 Attention: 19(1) AUG 15 1990 Dear Sirs: Re: Subsection 212(13.1) of the Income Tax Act and Article XI of the Canada-United States Income Tax Convention 1980 This is in reply to your letter dated March 15, 1990 whereby you requested our views as to the application of the above-noted provisions of the Income Tax Act and the Canada-United States Income Tax Convention, 1980 (the "Treaty") to interest paid by a partnership comprised entirely of U.S. resident individuals on a loan (not secured by real property situated in Canada or any interest therein) made by a U.S. bank to the partnership to finance the acquisition of Canadian rental property in respect of which the partners intend to make an election under section 216 of the Act. ...

Income Tax Convention Art. XI February 6, 1990 Mr. M.A. Hiltz Provincial and International Director Relations Division Re-Organizations and J. Wilson Non-Resident Division 957-2063 Attention: Ken Major EACC8732 Chief, Foreign Section 24(1)- SECURITY LENDING REVENUE CANADA- UNITED KINGDOM INCOME TAX CONVENTION We are writing in regard to an interpretation of Article XI, sub-paragraph 4(a) and paragraph 5 of the above-noted treaty. 24(1) has requested confirmation as to the tax treatment of income received by the 24(1) as compensation for Canadian Government Bonds loaned pursuant to a securities lending arrangement. 24(1) is of the opinion that the treaty exempts this income from Part XIII tax (copy of letter attached). ...

30 May 1990 Income Tax Severed Letter HBW 4125-F1 HBW 6591-F2 Unedited CRA Tags Canada-Finland Income Tax Convention HBW 4125-F1 HBW 6591-F2 Jim Wilson (613) 957-2063 May 30, 1990 Dear xxxxx Re: Finnish National Old Age Pension and Front Veterans Supplement We are writing in follow-up to our letter dated January 10, 1990 (copy attached), concerning the taxability in Canada of certain pension benefits received from Finland by a resident of Canada. ... The Finnish National Old Age Pension does not meet the definition of "pension" or "annuity" under Article II of the Canada-Finland Income Tax Convention (1958). ...

Income Tax Convention Art. 5, 33 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. ... Toussaint Jim Wilson Director General 957-2123 Attention: John Fennelly 921078 Offshore Activities- xxx Canada-United Kingdom Income Tax Convention (the "treaty") This is in reply to your memorandum of April 6, 1992 in which you requested confirmation of our previous comments made in our memorandum of July 12, 1991 regarding Article XXVIIA of the treaty. ...

Tax Convention Canada-U.S. Tax Treaty:Art. 11 This is in reply to your letter of May 20, 1986 concerning whether interest payments by certain Canadian institutions on debt obligations owing to residents of the United Kingdom (the "U.K. ... Income Tax Convention also exempts from the withholding tax rules, interest arising in Canada and paid to a resident of the U.K. if it is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by the United Kingdom Export Credit Guarantee Department. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Dear Sirs: This is in reply to your letter dated June 8, 1989. ... Income Tax Convention (1980). It is our understanding that in most cases this Canadian tax is creditable against U.S. income taxes. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII, Canada--Japan Tax Treaty article VIII 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. ... Tax Convention since such payment is not subject to the withholding tax under the Canadian income tax law. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XI This is in reply to your letter of May 21 concerning interest being paid by a Canadian bank to your grandmother, a U.S. resident and citizen. ... Income Tax Convention (1980), the rate of Canadian Part XIII tax on interest paid to a resident of the U.S. is 15%. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Dear Sirs: This is in reply to your memorandum of July 12, 1989 wherein you requested information concerning the tax treatment of payments made to a U.S. resident with respect to software purchases by a resident of Canada. ... Income Tax Convention reduces the withholding rate to 10 per cent where the use payments are made to a resident of the United States. ...