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Tax Convention Canada-U.S. Tax Treaty:Art. XVIII(3), XVIII(4) This is in reply to your letter of January 27, 1987 and further to your telephone conversion with us on February 16, 1987. ... Income Tax Convention (1980), there is no relief from the 25% Part XIII withholding tax on an IAAC. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII 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 (the "treaty', must be considered. Pursuant to Article XVIII of the treaty Canada maintains its right to tax pension income arising in the U.S. and paid to a resident of Canada to the extent such income would have been subject to tax in the U.S. had the recipient been a resident of the U.S.. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XVIII 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. ... The department of finance has recently released draft amendments to the Income Tax Conventions Interpretation Act which will affect the department's position stated above. ...

23 January 1998 Income Tax Severed Letter 9730077- Copyright royalties Unedited CRA Tags 212(1)(d)(1) SUMMARY: Copyright royalties—ITA-212(1)(d)(1)—Tax treatment of a royalty in respect of a copyright of a dramatic work for purposes of the Canada-United States Income Tax Convention. ... Income Tax Convention. We trust that our comments will be of assistence to you and we would be pleased to answer any further questions that you may have with respect to to this matter. ...

20 February 1998 Income Tax Severed Letter 9802875- Single purpose corporation Unedited CRA Tags 15(1) SUMMARY: Single purpose corporation—ITA-15(1)—Administrative policy regarding “single purpose corporations” used for the purpose of holding personal-use real estate including discussion of potential changes as a result of recent amendments to Article XXIX B of the Canada-United States Income Tax Convention. ... In light of the amendments to Article XXIX B of the Canada-United States Income Tax Convention which resolve many of the problems that confronted Canadian residents who owned or were contemplating the acquisition of personal use real property situated in the United States, the Department is reconsidering its administrative position with respect to such single purpose corporations. ...

Calderwood, Director Subject: Canada-Australia Income Tax Convention This is in reply to your Memorandum dated June 18, 1990 whereby you requested our opinion as to whether residents of Australia are exempt from Canadian tax liability in respect of capital gains realized on the disposition of taxable Canadian property, particularly shares in the capital stock of a corporation resident in Canada (other than a public corporation), by virtue of the Canada-Australian Income Tax Convention (1980) (the "Treaty"). ...

Tax Convention Canada-U.S. Tax Treaty:Art. X, XIII Dear Sirs: Re: Canada-U.S. Income Tax Convention (1980) (the “Treaty”) and Partnerships This is in response to your letter dated December 22, 1989 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

The branch operates at a loss and accordingly the taxpayer deducts the amount of the loss in calculating its income for both Canadian and United States income tax purposes pursuant to the provisions of the Canada-United States Tax Convention, such loss partly arising out of the fees paid to the controlled foreign affiliate; 4. ... While the service fee the branch is paying to the controlled foreign affiliate is deductible in computing income allocable to the United States, both under the Convention and pursuant to the source principle set forth in sections 3 and 4 of the Income Tax Act the resulting loss does reduce the income from the manufacturing operation allocated or sourced in Canada. ...

In addition, if a joint venture would be considered to have a permanent establishment in Canada for the purposes of an income tax convention that Canada has with another country, it if were a resident of a contracting state for the purposes of that convention, any member of such a joint venture who is resident in that country will generally be considered to have a permanent establishment in Canada. ...

It is essentially a question of fact, having regard to the definition in the applicable income tax convention or, if there is no applicable convention, Regulation 400(2), as to whether as a corporation has a permanent establishment in respect of its international shipping business in the country in which it is resident. ...