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Income Tax Convention (the "Convention") is ONLY APPLICABLE to persons who are RESIDENTS of Canada or the United States.  If you receive an amount from a U.S. pension plan AFTER you become a resident of Canada, the Convention should be applicable to you.      We are not aware of any provision in the Convention which would permit you to file an income tax return with the U.S. government in order to reduce your tax liability.  ...

ToussaintDirector General Attention: John Fennelly Offshore Activities- 24(1) 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.  ...

27 August 1993 Administrative Letter 9323666 F- Tax Treaty Negotiation Seminar (HAA 4093-U5-100-4) Unedited CRA Tags OECD Article 4, 250(3) MEMO FOR FILERulings Directorate Tax Treaty Negotiation Seminar (August 30 to September 3) Summary of Canadian Residence Concepts (Appendix A) Summary of the XXXXXXXXXX Case (Appendix B) Ken Major was asked to give a lecture concerning Articles 4 & 5 of the OECD Model Income Tax Convention in the above mentioned seminar organized with CIDA assistance for the XXXXXXXXXX The attached Appendixes were prepared, on an informal basis, as a handout for the participants during Mr. ... Meaning of "Centre of Vital Interest" in Canada's Income Tax Conventions Like residence determinations for an individual, a centre of vital interest determination, in all situations, must be based on an analysis of all the facts. ...

Income Tax Convention (the "treaty") Facts: On November 20, 1991 Doreen Guy (Ottawa D.O.) requested a technical interpretation regarding the above treaty articles. ...

Nevertheless, it is our view that such payments are subject to Canadian withholding tax under the Income Tax Act (the "Act") and are not exempted under the Canada-United States Income Tax Convention and Protocol (the "1942 treaty") or the Canada-U.S. Income Tax Convention (1980) (the "1980 treaty"). Subparagraph 212(1)(d)(i) of the Act and the 1980 Treaty Payments made under the License Agreement are for the use of the software in question rather than for the purchase of an ownership interest in the program or part thereof as is clarified in paragraphs 1) and 2) above. ...

Tax Convention.) Although we are unable to conclude that this leads to an inappropriate or anomalous result in the situation at hand, we note your suggestion that such might be the case where there are two taxation years in one day. ...

Arsenault   (613) 957-2126 Attention:  19(1) June 6, 1990 Dear Sirs: Re: Article XIII of the Canada-Italy Income Tax Treaty This is in reply to your letter of January 12, 1990 whereby you requested our interpretation of Article XIII of the Canada-Italy Income Tax Convention (1977) (the "Italian Treaty"). ...

Where annuity payments are received out of an RRSP by a person resident in Australia, the 25% Part XIII tax is reduced to 15% by virtue of Article 18 of the Canada-Australia Income Tax Convention Act, 1980. 3.      ...

The impact of the "tiebreaker" rule should also be pointed out under the heading "Calculation of Taxable Income". 3)     The example outlined in paragraph 3 on page 2 could be expanded to deal with the dual residency problem and the impact of the Canada-France Income Tax Convention on such a situation.  ...

However, such an individual may be entitled to relief from Canadian tax by virtue of the Canada United States Income Tax Convention, 1980 (the "Treaty"), if the individual is determined to be a resident of the United States for purposes of the Treaty. ...