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Current CRA website
Retiring allowances
If you pay a retiring allowance to a non-resident of Canada, withhold 25% of the retiring allowance (the withholding rates may vary depending on tax conventions and agreements). ...
Current CRA website
How to complete and file a Part XVIII Information Return – International Exchange of Information on Financial Accounts slips and summary
Tax Convention Income Tax Act: Part XVIII – Enhanced International Information Reporting FATCA foreign financial institution registration Page details Date modified: 2025-04-03 ...
Current CRA website
Current income tax interpretation bulletins (ITs)
IT-INDEX IT050- IT099 IT100- IT149 IT150- IT199 IT200- IT249 IT250- IT299 IT300- IT349 IT350- IT399 IT400- IT449 IT450- IT499 IT500- IT549 IT100- IT149 IT102R2 Conversion of property, other than real property, from or to inventory IT103R Dues paid to a union or to a parity or advisory committee CANCELLED- IT104R3 Deductibility of Fines or Penalties IT106R3 Crown Corporation Employees Abroad IT109R2 Unpaid Amounts CANCELLED- IT110R3 Gifts and Official Donation Receipts IT113R4 Benefits to Employees- Stock Options IT115R2 Fractional Interest in Shares IT116R3 Rights to Buy Additional Shares CANCELLED- IT119R4 Debts of Shareholders and Certain Persons Connected With Shareholders CANCELLED- IT120R6 Principal Residence IT123R6 Transactions Involving Eligible Capital Property IT124R6 Contributions to Registered Retirement Savings Plan IT125R4 Dispositions of Resource Properties IT126R2 Meaning of 'Winding up' CANCELLED- IT128R Capital cost allowance- Depreciable property IT129R Lawyers' trust accounts and disbursements IT131R2 Convention expenses IT137R3 Additional tax on certain corporations carrying on business in Canada IT137R3SR Additional Tax on Certain Corporations Carrying on Business in Canada IT140R3 Buy-sell agreements IT141R-CONSOLID Clergy Residence Deduction IT142R3 Settlement of debts on the winding-up of a corporation IT143R3 Meaning of Eligible Capital Expenditure IT146R4 Shares entitling shareholders to choose taxable or capital dividends CANCELLED- IT147R3 Capital cost allowance- Accelerated write-off of manufacturing and processing machinery and equipment IT148R3 Recreational Properties and Club Dues IT149R4 Winding-up Dividend Page details Date modified: 2025-04-10 ...
Current CRA website
8.1.2 Special Excise Warehouses
The following terms are used in this memorandum, as per section 2 Footnote 1: An accredited representative is a representative of a foreign country who is entitled to certain tax exemptions under the Foreign Missions and International Organizations Act as specified in Article 34 of the Convention set out in Schedule I of that Act, or in Article 49 of the Convention set out in Schedule II of that Act. ...
Current CRA website
Transfer pricing
It aims to resolve situations where taxpayers are subject to tax as a result of an audit adjustment that is not in accordance with the provisions of the relevant tax convention, including situations of double taxation. ... Tax treaties – Canada has income tax conventions or agreements—commonly known as tax treaties—with many countries. ...
Current CRA website
Information for entities holding accounts with Canadian financial institutions
Tax Convention and the Standard for Automatic Exchange of Financial Account Information in Tax Matters, respectively. ... Tax Convention to determine if it can certify that it is not a specified U.S. person. ... Tax Convention, respectively. Also, see the following: Guidance on the Canada-U.S. ...
Current CRA website
Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding
Income Tax Convention (“the Convention”). The LLC itself would have to attach Form NR303, Declaration of Eligibility for Benefits Under a Tax Treaty for a Hybrid Entity or equivalent information to the waiver application. On the other hand, if the LLC elects in the U.S. to be classified as a corporation and is taxable in the U.S. on its world income, it would be considered a resident of the U.S. for purposes of the Convention. ... LLC would be "liable to tax" in the U.S. for the purposes of paragraph 1 of Article IV of the Convention. ...
Current CRA website
Registering charities that promote racial equality
Racial discrimination is an identified social problem prohibited by an international convention to which most countries are signatories, making the promotion of racial equality an integral part of the public policy of many countries. ... Return to footnote1 referrer Footnote 2 These criteria are consistent with the United Nations International Convention on the Elimination of all forms of Racial Discrimination. ... Return to footnote3 referrer Footnote 4 Taken from the Canadian Anti-racism Education and Research Society: Defining Concepts and Terms Return to footnote4 referrer Footnote 5 Taken from the International Convention on the Elimination of All Forms of Racial Discrimination, 21 December 1965, General Assembly resolution 2106 (XX). ...
Current CRA website
Upholding human rights and charitable registration
Definitions 3.1 Human rights For the purposes of this document, the term human rights refers to those individual rights and freedoms, within their prescribed limitations, set out in: Canadian law, including: the Canadian Charter of Rights and Freedoms the Canadian Bill of Rights the Canadian Human Rights Act provincial and territorial human rights legislation international treaties to which Canada is a party that come within the following categories: United Nations human rights covenants, conventions, and protocols International Labour Organization conventions Geneva conventions and protocols Other human rights references not listed may serve as the basis for a charity's work if the relevant parts of their content are sufficiently similar to the human rights and freedoms recognized by Canada in the above documents. 3.2 Upholding human rights For the purposes of this document, upholding human rights refers to activities that seek to encourage, support, and defend human rights that have been secured by law, both in Canada and abroad. ... When the English court decided the McGovern case in 1981, the United Kingdom had not yet ratified certain key human rights conventions or enacted measures to uphold the relevant human rights. ... Purposes may include, but are not limited to: monitoring and reporting on the fulfillment of human rights obligations (under convention or treaty x, in country or region y, or the whole world) upholding human rights law (under convention or treaty x, in country or region y, or the whole world) seeking legal remedies for victims of human rights abuses Example purpose and activities To uphold the administration and enforcement of (specify the international covenant or agreement) throughout the world, through the following activities: creating and disseminating reports that outline the progress of signatory countries on the administration and enforcement of the (specified covenant or agreement) providing training to government officials, lawyers, and judges in countries that are signatory to the (specified covenant or agreement) providing well-reasoned commentary and recommendations to the signatory governments about the implementation of the (specified covenant or agreement) providing legal advice and representation to victims of violations of the (specified covenant or agreement) for attempts to obtain remedies through the courts of the country concerned or any available international remedies Preserving human life and health In these cases, the focus will tend to be on the victims of human rights abuses. ...
Current CRA website
TPM-06
The relevant tax convention must then be examined to determine whether there is any tax relief provided therein, such as an exemption or a reduction in the Part XIII withholding rate. ... It is important to note that Article XII of the Canada-United States Tax Convention (1980) was amended in the Third Protocol (1995) to expand the class of royalties exempt from withholding tax at source. ... Return to footnote3 referrer Footnote 4 Model Tax Convention on Income and on Capital, Organization for Economic Co-Operation and Development (2003) Commentary on Article 12, paragraph 11.4. ...