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Also, see 15 below for the special rule concerning conference, convention and seminar expenses. ¶ 2. ... Conferences, Conventions and Seminars ¶ 15. Subsection 67.1(3) may apply when a fee is paid or payable for attendance at a conference, convention, seminar or similar event and that fee entitles the participant to food, beverages or entertainment. ... For a more detailed discussion of this topic, refer to the current version of IT-131, Convention Expenses. ...

Also, see 15 below for the special rule concerning conference, convention and seminar expenses. ¶ 2. ... Conferences, Conventions and Seminars ¶ 15. Subsection 67.1(3) may apply when a fee is paid or payable for attendance at a conference, convention, seminar or similar event and that fee entitles the participant to food, beverages or entertainment. ... For a more detailed discussion of this topic, refer to the current version of IT-131, Convention Expenses. ...

Convention on Mutual Administrative Assistance in Tax Matters The Organization of Economic Cooperation and Development (“OECD”) – Council of Europe (“CoE”) Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”) entered into force in April 1995 when five states, Denmark, Finland, Norway, Sweden and the United States ratified the Convention. At this time the Convention is in force in 11 countries and three other countries, including Canada, have signed or ratified the Convention but cannot yet apply the Convention. ... The application of the Convention will be similar to the application of our bilateral tax conventions that already provide for the exchange of information. ...

Convention on Mutual Administrative Assistance in Tax Matters The Organization of Economic Cooperation and Development (“OECD”) – Council of Europe (“CoE”) Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”) entered into force in April 1995 when five states, Denmark, Finland, Norway, Sweden and the United States ratified the Convention. At this time the Convention is in force in 11 countries and three other countries, including Canada, have signed or ratified the Convention but cannot yet apply the Convention. ... The application of the Convention will be similar to the application of our bilateral tax conventions that already provide for the exchange of information. ...

Charitable Donations and the Canada-United States Income Tax Convention The Canada-United States Income Tax Convention (1980), referred to here as "the Treaty," is an agreement that allows residents of the two countries to avoid double taxation on income and on capital. ...

Charitable Donations and the Canada-United States Income Tax Convention The Canada-United States Income Tax Convention (1980), referred to here as "the Treaty," is an agreement that allows residents of the two countries to avoid double taxation on income and on capital. ...

Response 1 As stated in Article I of the Convention, the Convention is generally applicable to persons who are residents of either Canada or the United States, or both Canada and the United States. ... Question 2 Has the CRA made any determinations under this provision of the Convention in the past? ... Income Tax Convention (the “Convention”)? Response The CRA has examined several state limited liability company statutes, but not all. ...

Response 1 As stated in Article I of the Convention, the Convention is generally applicable to persons who are residents of either Canada or the United States, or both Canada and the United States. ... Question 2 Has the CRA made any determinations under this provision of the Convention in the past? ... Income Tax Convention (the “Convention”)? Response The CRA has examined several state limited liability company statutes, but not all. ...

The Commentary to Article 1 of the OECD Model Tax Convention on Income and on Capital states, in part, at paragraph 9.4: … it is agreed that states do not have to grant the benefits of a double taxation convention where arrangements that constitute an abuse of the provisions of the convention have been entered into. ... However, in the Canada-U.S tax convention, Canada has specifically agreed to give a foreign tax credit for payments under the Federal Insurance Contributions Act, more commonly known as FICA taxes. ...

The Commentary to Article 1 of the OECD Model Tax Convention on Income and on Capital states, in part, at paragraph 9.4: … it is agreed that states do not have to grant the benefits of a double taxation convention where arrangements that constitute an abuse of the provisions of the convention have been entered into. ... However, in the Canada-U.S tax convention, Canada has specifically agreed to give a foreign tax credit for payments under the Federal Insurance Contributions Act, more commonly known as FICA taxes. ...