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The part of the payment that is deducted because it is exempt from tax under a tax convention or agreement is not eligible to be transferred. ...

International Legal Framework Subparagraph 241(4)(e)(xii) of the Income Tax Act – The authority to share taxpayer information collected by the CRA with another jurisdiction under the provision contained in a tax treaty, a comprehensive tax information exchange agreement, or the Convention on Mutual Administrative Assistance in Tax Matters. Convention on Mutual Administrative Assistance in Tax Matters Common Reporting Standard Multilateral Competent Authority Agreement Canada’s tax conventions and tax agreements Competent Authority Agreement Summary of the project, initiative or change Overview of the Program or Activity The Common Reporting Standard is a legislative framework for the standardization of information maintained and reported by financial institutions, in relation to accounts held by non-resident individuals and entities. ... The provision of Part XIX information to foreign governments is permitted under subparagraph 241(4)(e)(xii) of the Income Tax Act, which allows for the exchange of taxpayer information between two competent authorities representing a tax treaty or the Convention on Mutual Administrative Assistance in Tax Matters. ...

Organizations- Under Article XXI of the Canada- United States Tax Convention T4036 Rental Income T4037 Capital Gains T4055 Newcomers to Canada T4058 Non-Residents and Income Tax T4061 Non-Resident Withholding Tax Guide T4144 Income Tax Guide for Electing Under Section 216 T4145 Electing Under Section 217 of the Income Tax Act T4155 Old Age Security Return of Income Guide for Non-Residents Forms 5013-D1 Federal Worksheet for Non-Residents- T1 General 5013-R T1 General- Income Tax Benefit Return for Non-Residents and Deemed Residents of Canada 5013-SA Schedule A- Statement of World Income for Non-Residents and Deemed Residents of Canada- T1 General 5013-SB Schedule B- Allowable Amount of Non-Refundable Tax Credits for Non-Resident and Deemed Residents of Canada- T1 General 5013-SC Schedule C- Electing Under Section 217 of the Income Tax Act for Non-Resident and Deemed Residents of Canada- T1 General CTB9 Canada Child Tax Benefit Statement NR4 Statement of Amounts Paid or Credited to Non-Residents of Canada NR4SUM Return of Amounts Paid or Credited to Non-Residents of Canada NR4(OAS) Statement of Old Age Security Pension Paid or Credited to Non-Residents of Canada NR5 Application by a Non-Resident of Canada for a Reduction in the Amount of Non-Resident Tax Required to be Withheld NR6 Undertaking to File an Income Tax Return by a Non-Resident Receiving Rent from Real Property or Receiving a Timber Royalty NR601 Non-Resident Ownership Certificate (Withholding Tax) NR602 Non-Resident Ownership Certificate (No Withholding Tax) NR603 Remittance of Non-Resident Tax on Income from Film or Video Acting Services NR7-R Application for Refund of Non-Resident Part XIII Tax Withheld NR73 Determination of Residency Status (Leaving Canada) NR74 Determination of Residency Status (Entering Canada) NRTA1 Authorization for Non-Resident Tax Exemption R105 Regulation 105 Waiver Application RC1 Request for a Business Number (BN) RC151 GST/HST Credit Application for Individuals Who Become Residents of Canada RC59 Business Consent Form RC66 Canada Child Benefits Application T106 Information Return of Non-Arm's Length Transactions with Non-Residents T1131 Claiming a Canadian Film or Video Production Tax Credit T1134 Information Return Relating To Controlled and Not-Controlled Foreign Affiliates T1135 Foreign Income Verification Statement T1136 Old Age Security Return of Income T1141 Information Return in Respect of Transfers or Loans to a Non-Resident Trust T1142 Information Return in Respect of Distributions from and Indebtedness to a Non-Resident Trust T1159 Income Tax Return for Electing Under Section 216 T1161 List of Properties by an Emigrant of Canada T1177 Claiming a Film or Video Production Services Tax Credit T1243 Deemed Disposition of Property by an Emigrant of Canada T1244 Election, Under Subsection 220(4.5) of The Income Tax Act, to Defer the Payment of Tax on Income Relating to the Deemed Disposition of Property T1248 Schedule B, Allowable Amount of Non-Refundable Tax Credits; and Schedule D, Information About Your Residency Status T1261 Application for a Canada Revenue Agency Individual Tax Number (ITN) for Non-Residents T1262 Part XIII.2 Tax Return for Non-Resident's Investments in Canadian Mutual Funds T1287 Application by a Non-Resident of Canada (Individual) for a Reduction in the Amount of Non-Resident Tax Required to be Withheld on Income Earned From Acting in a Film or Video Production T1288 Application by a Non-Resident of Canada (Corporation) for a Reduction in the Amount of Non-Resident Tax Required to be Withheld on Income Earned From Acting in a Film or Video Production T2 Corporation Income Tax Return T2SCH19 Non-Resident Shareholder Information T2SCH20 Part XIV- Additional Tax on Non-Resident Corporations T2SCH91 Information Concerning Claims for Treaty Based Exemptions T2SCH97 Additional Information On Non-Resident Corporations In Canada T2016 Part XIII Tax Return- Tax on Income from Canada of Approved Non-Resident Insurers T2023 Election in Respect of Loans from Non-Residents T2047 Agreement in Respect of Unpaid Amounts T2061A Election by an Emigrant to Report Deemed Dispositions of Taxable Canadian Property and Capital Gains and/or Losses Thereon T2062 Request by a Non-Resident of Canada for a Certificate of Compliance Related to the Disposition of Taxable Canadian Property T2062A Request by a Non-resident of Canada for a Certificate of Compliance Related to the Disposition of Canadian Resource or Timber Resource Property, Canadian Real Property (Other Than Capital Property), or Depreciable Taxable Canadian Property T2062ASCH1 Disposition of Canadian Resource Property by Non-Residents T2062B Notice of Disposition of a Life Insurance Policy in Canada by a Non-Resident of Canada T2062BSCH1 Certification and Remittance Notice T2062C Notification of an acquisition of treaty-protected property from a non-resident vendor T2091 (IND) Designation of a Property as a Principal Residence by an Individual (Other than a Personal Trust) T2091(IND)-WS Principal Residence Worksheet T2203 Provincial and Territorial Taxes- Multiple Jurisdictions T3RET T3 Trust Income Tax and Information Return T4A-NR Statement of Fees, Commissions, or Other Amounts Paid to Non-Residents for Services Rendered in Canada T4ANRSUM Summary of Fees, Commissions, or Other Amounts Paid to Non-Residents for Services Rendered in Canada T626 Overseas Employment Tax Credit (for 2002 and subsequent years) T776 Statement of Real Estate Rentals TL11D Tuition Fees Certificate- Educational Institution Outside Canada for a Deemed Resident of Canada TX19 Asking for a Clearance Certificate Other publications IC71-17R5 Guidance on Competent Authority Assistance Under Canada's Tax Conventions IC72-17R6 Procedures Concerning the Disposition of Taxable Canadian Property by Non-Residents of Canada- Section 116 IC75-6R2 Required Withholding From Amounts Paid to Non Residents Providing Services in Canada IC76-12R6 Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention IC77-16R4 Non-Resident Income Tax IC77-9R Books, Records and Other Requirements for Taxpayers Having Foreign Affiliates IC82-6 Clearance Certificate IC94-4R International Transfer Pricing: Advance Pricing Arrangements (APAs) IC94-4RSR Special Release- Advance Pricing Arrangements for Small Businesses IT76R2 Exempt portion of pension when employee has been a non-resident IT109R2 Unpaid Amounts IT137R3 Additional tax on certain corporations carrying on business in Canada IT137R3SR Additional Tax on Certain Corporations Carrying on Business in Canada IT155R3 Exemption from non-resident tax on interest payable on certain bonds, debentures, notes, hypothecs or similar IT155R3SR Exemption from non-resident tax on interest payable on certain bonds, debentures, notes, hypothecs or similar obligations IT221R3-CONSOLID Determination of an Individual's Residence Status IT270R3 Foreign tax credit IT303 Know-how and similar payments to non-residents IT303SR Know-how and similar payments to non-residents IT360R2 Interest payable in a foreign currency IT361R3 Exemption From Part XIII Tax on Interest Payments to Non-Residents IT393R2 Election Re: Tax on Rents and Timber Royalties Non-Residents IT420R3SR Non-Residents- Income Earned in Canada IT434R Rental of real property by individual IT447 Residence of a Trust or Estate IT451R Deemed disposition and acquisition on ceasing to be or becoming resident in Canada IT465R Non-Resident Beneficiaries of Trusts IT468R Management or administration fees paid to non-residents IT489R Non-Arm's Length Sale of Shares to a Corporation IT494 Hire of ships and aircraft from non-residents IT497R4 Overseas Employment Tax Credit Report a problem or mistake on this page Thank you for your help! ...

Income Tax Convention, Canada has the right to tax a resident of the United States who is providing services in Canada only if the person has a fixed base/PE in Canada. ... PE determinations In general, PE determinations should be made in light of the particular words of a treaty, the jurisprudence, and the Commentary on the Organisation for Economic Cooperation and Development (OECD) Model Tax Convention on Income and Capital (OECD Commentary), taking into consideration departures of the particular treaty from the OECD Model Tax Convention on Income and Capital (OECD Model). ... Income Tax Convention. Additionally, if a non-resident employer is determined not to have a PE in Canada its non-resident employees providing services in Canada are still subject to withholding under section 102 of the Income Tax Regulations (see the current version of information circular IC75-6R, Required Withholding from Amounts Paid to Non-residents Providing Services in Canada). ...

If you want to adjust another type of return (such as Form GST106, Information on Claims Paid or Credited for Foreign Conventions and Tour Packages), send your request in writing to your tax centre. ...

If you want to adjust another type of return (such as Form GST106, Information on Claims Paid or Credited for Foreign Conventions and Tour Packages), send your request in writing to your tax centre. ...

Income Tax Act, subsection 212(4) or business profits article of a tax convention signed by Canada Exemptions for payments made to non-resident tax-exempt persons Exemption code for payments made to non-resident tax-exempt persons Code Description References I Article XXI of the Canada − United States Tax Convention: Exemption for organizations that have received a letter of exemption under Article XXI of the Canada – United States Tax Convention. ... Organizations- Under Article XXI of the Canada- United States Tax Convention Other exemptions Exemption codes for other exemptions Code Description References Q Payments to a non-resident that carries on a business in Canada through a permanent establishment in Canada: Exemption under a tax convention between Canada and another country on dividend, interest, and royalty payments. ... T Other exempting provisions: Exemption from withholding tax as a result of other exempting provisions of a tax convention, other than those given above in codes I, and P through R. ...

. ¶1.10 has been added to note the amendments to section 4.3 of the Income Tax Conventions Interpretations Act as it relates to the deemed residence of a trust under subsection 94(3). ¶1.11 (formerly ¶10 of IT-447) has been amended to reflect the legislative change made by S.C. 2013, c. 40 (formerly Bill C-4) that a trust must be resident in Canada in order for the attribution rule in subsection 75(2) to apply in respect of property held by the trust. ¶1.12 has been added to note that subsection 250(6.1) will deem a trust that ceases to exist at any time in a tax year, and that was resident in Canada immediately before it ceased to exist, to be resident in Canada during the remaining period in the year. ...

Organizations- Under Article XXI of the Canada- United States Tax Convention. ... Income Tax Act, subsection 212(4) or business profits article of a tax convention signed by Canada Exemptions for payments made to non-resident tax-exempt persons Exemption code for payments made to non-resident tax-exempt persons Code Description References I Article XXI of the Canada − United States Tax Convention: Exemption for organizations that have received a letter of exemption under Article XXI of the Canada − United States Tax Convention. ... T Other exempting provisions: Exemption from withholding tax as a result of other exempting provisions of a tax convention, other than those given above in codes I, and P through R. ...

. ¶1.10 has been added to note the amendments to section 4.3 of the Income Tax Conventions Interpretations Act as it relates to the deemed residence of a trust under subsection 94(3). ¶1.11 (formerly ¶10 of IT-447) has been amended to reflect the legislative change made by S.C. 2013, c. 40 (formerly Bill C-4) that a trust must be resident in Canada in order for the attribution rule in subsection 75(2) to apply in respect of property held by the trust. ¶1.12 has been added to note that subsection 250(6.1) will deem a trust that ceases to exist at any time in a tax year, and that was resident in Canada immediately before it ceased to exist, to be resident in Canada during the remaining period in the year. ...