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Income Tax Convention (the “Convention”). In addition, over the past XXXXXXXXXX years, several reorganizations of capital have occurred within XXXXXXXXXX and XXXXXXXXXX. ... Any assets of the Canadian Group that are of the nature described in paragraph 4 of Article 13 of the Convention and any assets of the Canadian Group that are leased or rented to third parties or other members of the XXXXXXXXXX Group, are immaterial to the issues dealt with in this ruling request. ... For the purposes of subparagraph 7(b) of Article 13 of the Convention, the XXXXXXXXXX Properties are properties (other than rental properties) in which the business of the company is carried on and therefore do not constitute immovable property under paragraph 5 of Article 13; B. ...

Pour se faire, une convention de gestion (ci-après la “Convention”) est conclue entre ABC et SPXY. ... La Convention prend fin au moment où la totalité des produits de la vente de la saison est encaissée. ... Le fait que SPXY gère l'entreprise de ABC selon la Convention ne fait pas en sorte que l'entreprise de ABC devienne l'entreprise de SPXY. ...

Income Tax Convention? 4. Can the taxpayer claim a foreign tax credit in XXXXXXXXXX for the tax withheld by XXXXXXXXXX? ... If our conclusions are correct, the U.S. has taxed in accordance with the Convention. 4. ... If that is the case, the only remaining provision that may be relevant is Article XXII of the Convention, which states that income arising in the U.S. may be taxed in the U.S, without reduction by the Convention.Assuming that this is the correct interpretation of the U.S. domestic law and the U.S.'s application of the Convention, Canada is obliged to provide relief from double taxation. ...

Spice 24(1) (613) 957-8953 Attention: 19(1) July 24, 1992 Dear Sirs: Re: Request for Technical Interpretation 24(1) This is in reply to your letter of June 5, 1992, in which you ask for a technical interpretation of various sections of the Income Tax Act (the "Act") and Article XV of the Canada-Switzerland Income Tax Convention. ... A Swiss resident who is taxed in Switzerland on amounts out of the EBP in accordance with Article XV of the Canada- Switzerland Income Tax Convention would be entitled to a deduction under subparagraph 110(1)(f)(i) of the Act. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII Dear Sirs: This is in reply to your letter of April 13, 1987 regarding the taxation of pension benefits to be received from a Canadian company pension plan in respect of which you made contributions in part with tax-paid dollars while living in the United States. ... Income Tax Convention (1980). However, paragraph 212(1)(h) of the Act may provide for an exemption from non-resident withholding tax with respect to a portion of the pension benefits. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII, XXII Dear Sirs: This is in reply to your letter of December 17, 1986 requesting that we confirm your understanding of a number of issues related to non-resident withholding requirements of payments for live television programming. ... Income Tax Convention (the "Treaty"). As a result they may be subject to a withholding tax of 25% by virtue of paragraph 212(1)(d) of the Act and Article 22 of the Treaty unless, of course, they are considered business profits t-o the non-resident and the non-resident does not have a permanent establishment in Canada. ...

Tax Convention (1978), is that management or administrative fees or charges would constitute a part of same. ... " Accordingly, where management fees are paid to a non-resident of a treaty country and the convention with that country does not deal specifically with management fees but simply contains the above-mentioned "business profits" article, the non-resident will not be subject to tax in Canada unless the charges can be said to be related to a business carried on by it in Canada through a permanent establishment. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XIII Can we apply subsection 55(10 in a situation where a capital gain is eliminated in a manner which would appear to be offensive from a policy perspective. ... Tax Convention (the "Treaty"). By increasing the paid-up capital of the classes of shares held by the trusts, the trusts will be subject to Part XIII tax of 15% by virtue of subsections 84(1) and 212(2) and Article 10 of the Treaty. ...

Tax Convention. Article VII (and not Article I) would be the applicable provision, since it deal-s explicitly with compensation for personal services. Consequently, the consulting fees are not exempted from Canadian tax by virtue of the Convention. ...

Tax Convention Canada-U.S. Tax Treaty:Art. III(1)(h), VIII(1), VIII(2)(a), XII(2), XII(4), XII(6)(b) Dear XXX: This is in reply to your letter of October 29, 1984 concerning the income tax consequences of paragraph 212(1)(d) and subsection 212(13) of the Income Tax Act (the "Act") and Articles III(1)(h), VIII(1) and (2)(a) and XII(2), (4) and (6)(b) of the 1980 Canada-U.S. Income Tax Convention (the "Treaty") in the circumstances described. ...