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Under the Canada-France Income Tax Convention and the Canada-Netherlands Income Tax Convention, you may be able to deduct, under certain circumstances, contributions to a pension plan. ...

The purpose of this Special Release is to revise the bulletin (1) to reflect an amendment to the 1980 Canada-United States Income Tax Convention (the "1980 Convention") as contained in the third Protocol, signed on March 17, 1995, to the 1980 Convention, (2) to reflect an amendment to the Income Tax Act contained in S.C. 1994 c. 7 (formerly Bill C-15 and before that Bill C-92), (3) to clarify certain paragraphs, and (4) to delete a paragraph that has no current relevance. ... Paragraph 10 of the bulletin is revised to reflect an amendment to paragraph 8 of Article XIII of the 1980 Convention. ... Paragraph 9 of Article XIII of the 1980 Convention provides a transitional rule reflecting the fact that, under Article VIII of the 1942 Canada-United States Income Tax Convention (the "1942 convention"), gains derived by a resident or corporation or other entity of the United States from the sale or exchange of capital assets located in Canada were exempt from tax in Canada provided that such resident or corporation or other entity did not have a permanent establishment in Canada at any time in the taxation year during which the sale or exchange occurred. ...

The purpose of this Special Release is to revise the bulletin (1) to reflect an amendment to the 1980 Canada-United States Income Tax Convention (the "1980 Convention") as contained in the third Protocol, signed on March 17, 1995, to the 1980 Convention, (2) to reflect an amendment to the Income Tax Act contained in S.C. 1994 c. 7 (formerly Bill C-15 and before that Bill C-92), (3) to clarify certain paragraphs, and (4) to delete a paragraph that has no current relevance. ... Paragraph 10 of the bulletin is revised to reflect an amendment to paragraph 8 of Article XIII of the 1980 Convention. ... Paragraph 9 of Article XIII of the 1980 Convention provides a transitional rule reflecting the fact that, under Article VIII of the 1942 Canada-United States Income Tax Convention (the "1942 convention"), gains derived by a resident or corporation or other entity of the United States from the sale or exchange of capital assets located in Canada were exempt from tax in Canada provided that such resident or corporation or other entity did not have a permanent establishment in Canada at any time in the taxation year during which the sale or exchange occurred. ...

Income Tax Convention (1980) may affect the taxation of such payments where the beneficial owner of the royalties is a resident of the United States. ... Income Tax Convention (1978) provides rules similar to those of the Canada-United States. Income Tax Convention (1980). Date modified: 1995-01-01 ...

A distinction should therefore be made between a training course and a convention or a business meeting. ... Conventions and Business Meetings 9. A training course should be distinguished from a convention, which may be described as a formal meeting of members of an organization or association for professional or business purposes. ... It is a question of fact whether a "seminar" is a convention or a training course. ...

A distinction should therefore be made between a training course and a convention or a business meeting. ... Conventions and Business Meetings 9. A training course should be distinguished from a convention, which may be described as a formal meeting of members of an organization or association for professional or business purposes. ... It is a question of fact whether a "seminar" is a convention or a training course. ...

Computer Software In the Commentary on Article 12 of the OECD Model Tax Convention on Income and Capital (April 29, 2000 condensed version) concerning the taxation of royalties, at paragraph 27, Canada has an observation that states: Canada does not adhere to paragraphs 14 through 14.3. ... Accordingly, as of March 28, 2002, for the purposes of Canada's Income Tax Conventions, subject to the exceptional cases described in paragraph 14.3 of the commentary on Article 12, the CCRA will no longer view such a payment as a payment for a "secret formula" and the CCRA will apply this interpretation for the Conventions in force as of March 28, 2002 and subsequent Conventions that come into force after that date. However, the CCRA does view such a payment as a "royalty" where the definition of "royalty" in the particular Convention refers to "payments... for the use of, or the right to use... other intangible property". ...

Computer Software In the Commentary on Article 12 of the OECD Model Tax Convention on Income and Capital (April 29, 2000 condensed version) concerning the taxation of royalties, at paragraph 27, Canada has an observation that states: Canada does not adhere to paragraphs 14 through 14.3. ... Accordingly, as of March 28, 2002, for the purposes of Canada's Income Tax Conventions, subject to the exceptional cases described in paragraph 14.3 of the commentary on Article 12, the CCRA will no longer view such a payment as a payment for a "secret formula" and the CCRA will apply this interpretation for the Conventions in force as of March 28, 2002 and subsequent Conventions that come into force after that date. However, the CCRA does view such a payment as a "royalty" where the definition of "royalty" in the particular Convention refers to "payments... for the use of, or the right to use... other intangible property". ...

Computer Software In the Commentary on Article 12 of the OECD Model Tax Convention on Income and Capital (April 29, 2000 condensed version) concerning the taxation of royalties, at paragraph 27, Canada has an observation that states: Canada does not adhere to paragraphs 14 through 14.3. ... Accordingly, as of March 28, 2002, for the purposes of Canada's Income Tax Conventions, subject to the exceptional cases described in paragraph 14.3 of the commentary on Article 12, the CCRA will no longer view such a payment as a payment for a "secret formula" and the CCRA will apply this interpretation for the Conventions in force as of March 28, 2002 and subsequent Conventions that come into force after that date. However, the CCRA does view such a payment as a "royalty" where the definition of "royalty" in the particular Convention refers to "payments... for the use of, or the right to use... other intangible property". ...

GST/HST registrants that may have to file form GST106 include: with respect to eligible tour packages, a GST/HST registrant that pays or credits the rebate amount to a non-resident, non-registered tour operator or to a non-resident individual, business, or organization; and with respect to foreign conventions: a GST/HST registrant organizer of a foreign convention that pays or credits the rebate amount to the sponsor; a GST/HST registrant operator of a convention facility that is not the organizer of a foreign convention that pays or credits the rebate amount to the sponsor or the non-registered organizer; and a GST/HST registrant supplier of short-term or camping accommodation that is not the organizer of a foreign convention that pays or credits the rebate amount to the sponsor or the non-registered organizer. ... For more information, go to GST/HST Information for the Travel and Convention Industry. ... Further information Further information on the FCTIP and filing form GST106 is available on the CRA Web site: GST/HST Memorandum 27-2, Conventions GST/HST Memorandum 27-3, Foreign Convention and Tour Incentive Program – Rebate for Eligible Tour Packages and Accommodation Supplied as Part of Eligible Tour Packages GST/HST Info Sheet GI-031, Foreign Convention and Tour Incentive Program- Registrant Organizers and Convention Facility Operators: Paying and Crediting the Rebate Amount for Foreign Conventions GST/HST Info Sheet GI-032, Non-Residents Purchasing Tour Packages: Rebate for Eligible Tour Packages Guide RC4036, GST/HST Information for the Travel and Convention Industry Residential care A provision of the Excise Tax Act exempts a supply of a service of providing care, supervision and a place of residence to children, underprivileged individuals or individuals with a disability in an establishment operated by the supplier for the purpose of providing such services. ...