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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 ("the Treaty"). Since the situation which we pose herein is hypothetical, a formal ruling is not appropriate at this time. ... Tax Convention, the Treaty contains no specific reference to place of incorporation. ...

Article XXI of the Canada-United Kingdom Income Tax Convention (Convention) states that "Subject to the existing provisions of the law of Canada... tax payable in the United Kingdom on profits, income or gains arising in the United Kingdom shall be deducted from any Canadian tax payable in respect of such profits, income or gains. ...

Tax Convention it appeared doubtful that Part XI.3 Tax which was not specifically dealt with in this treaty could be applied to a U.S. entity not resident in Canada. ... Consequently, it appeared Article II may bring this tax within the scope of the Convention. ...

Tax Convention- Article 17 and Section 217 Election under the Income Tax Act We are writing to request an interpretation of the treatment to be accorded pension income received by a U.K. resident from Canada where a section 217 election is made under the Income Tax Act. ... Tax Convention as revised by the 1985 protocol provides in Article 17 that the hypothetical taxpayer mentioned above will be taxed only in the U.K. on pension income received from Canada. ...

Tax Convention it appeared doubtful that Part XI.3 Tax which was not specifically dealt with in this treaty could be applied to a U.S. entity not resident in Canada. ... Consequently, it appeared Article II may bring this tax within the scope of the Convention. ...

Short was passed on to us for reply since the responsibility for carrying out the provisions of the Income Tax Conventions, once they have come into force, rests with this department. ... When a Canadian payor makes a payment to a person in Austria which qualifies for exemption under either Article XI or XII of our Income Tax Convention he need not withhold tax, even though he has received no other certification of exemption. ...

Carol Muirhead, Chief Non-Resident, Business & Property Income Section Non-Corporate Rulings Division DEPARTMENT OF NATIONAL REVENUE, TAXATION 88 Metcalfe Street 5th Floor Ottawa, Ontario K1P 5L7 Re: Application of Canada- Belgium Income Tax Convention Dear Ms. Muirhead: We have written concerning the application of the Canada- Belgium Income Tax Convention of 1976, (hereinafter referred to as the "Treaty"), with respect to the possible disposition by a former Canadian resident of shares held by him prior to his departure from Canada. 1. ...

Les modifications qui s'appliqueront généralement aux années d'imposition commençant après 1988, ont été effectuées pour s'harmoniser avec certaines dispositions que l'on retrouve fréquemment dans les conventions entre actionnaires relativement à l'achat et à la vente d'actions. En tenant compte de ce qui précède, nous sommes d'avis qu'il y aurait lieu de ne pas appliquer les dispositions de l'alinéa 251(5)b) de la Loi à l'égard du droit décrit à la clause 8.2.3 de la convention entre actionnaires XXXX Chef de section intérimaire Section des services bilingues (spécialités) Division des services bilingues et des industries d'exploitation des ressources Direction des décisions ...

In order to claim an exemption under Article XVIII(1) of the Convention the onus of establishing that the amount of "pension" in question is in fact excluded from taxable income in the United States falls upon the resident of Canada who claims that exemption. We suggest that you obtain appropriate written confirmation from the United States authorities and be prepared to support your client's 1989 claim for an exemption under Article XVIII(1) of the Convention. ...