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Income Tax Convention (1980). With respect to your first query, it remains our opinion that notwithstanding the deeming provisions of the United States Internal Revenue Code, an “S” corporation for Canadian tax purposes is considered to be a corporation under U.S. corporate law and as such, absent any FAPI implications, a Canadian resident shareholder thereof is only subject to Canadian income tax on amounts received from or benefits conferred by the “S” corporation and is not subject to such tax on the undistributed earnings of that corporation. ... Income Tax Convention (1980). We trust that this information will be of assistance to you. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VII Dear Sirs: This is in reply to your letter dated February 1, 1988 wherein you requested our opinion on the tax consequences of a sale by a United States resident of a trade mark and design mark registered in Canada. ... Therefore, if the United States resident has a permanent establishment in Canada, he could be subject to tax on that income pursuant to section 14 of the Act and Article VII of the Canada-United States Income Tax Convention (1980). ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Subject: Copyright Royalties and Cable Company Retransmissions This is in reply to your memorandum of October 30, 1990 wherein you requested we review the opinion expressed therein with respect to the treatment of payments to be made by cable companies and other retransmitters to U.S. residents for the right to retransmit distant television and radio signals. ... Income Tax Convention permits Canada to tax such royalty payments made to U.S. residents, however, the rate of withholding tax on such payments is limited to 10% of the gross amount of the royalty payments. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Dear Sir: Re: Disability Payments made to Non-Resident This is in reply to your letter dated March 19, 1991 whereby you requested our opinion in respect of the following hypothetical fact situation: Facts If the taxpayer had remained resident in Canada, the payments in question would have been taxable under paragraph 6(1)(f). ... By virtue of subparagraph 2(a) of Article XVIII of the Canada-United States Income Tax Convention, 1980, the tax that Canada may impose on the payments here in question will be limited to an amount not in excess of 15 percent of the gross amount of such payments provided the plan qualifies as a pension as defined in paragraph 3 of that Article. ...

7 April 1991 Income Tax Severed Letter- Correspondance of France Pension Plan a Pension Plan Recognized for Canadian Tax Purposes Unedited CRA Tags 6(1)(a), Canada-France Tax Convention (1975) Article 29 Dear Sirs: Re: Our letter of April 4, 1991 Further to the above-noted letter and our telephone conversation of April 15, 1991, this is to advise that Article 29 of the Canada-France Tax Convention (1975) contains a provision which may be applicable to the situation on which you asked us to comment. ...

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information Where the beneficial owner of the interest is a resident of Belgium under the Canada-Belgium Income Tax Convention, or a resident of the Netherlands under the Canada-Netherlands Income Tax Convention, the tax so charged shall not exceed 15% of the gross amount of the interest. ...

6 May 1986 Income Tax Severed Letter 5-1045 Unedited CRA Tags 212(1)(d), Canada-Norway Income Tax Convention article II 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. ... Dear XXX This is in reply to your letter of February 13, 1986 in which you request our opinion on whether Article II of the Canada-Norway Income Tax Convention (the "treaty") exempts residents of Norway from Canadian tax in respect of rental income from moveable property. ...

Income Tax Convention Art. XII 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 (1978). In response to your concern about the possibility of double taxation, we agree that this may result. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII 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 (1980). Hence, the Canadian payor is obligated, pursuant to subsection 215(1) of the Income Tax Act, to withhold the applicable 10% rate of tax and remit same to the Receiver General by the 15th day of the month following the month in which the tax was withheld. ...

16 March 1988 Income Tax Severed Letter 5-3872 Unedited CRA Tags Canada-Netherlands Income Tax Convention articles 4 and 10 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. ... Dear Sirs: This is in reply to your letter of September 11, 1987 in which you requested our opinion on interpreting Articles 4 and 10 of the Canada-Netherlands Income Tax Convention (1986) (the "Treaty") as they apply to a Dutch pension fund which is exempt from income tax in the Netherlands under the Dutch income tax act. ...