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Generally speaking, it is our view that for purposes of determining income tax liability as may be reduced by agreements or conventions, a partnership should be treated as a conduit except for those jurisdictions where the partnership is taxed as a separate entity.  ... Income Tax Convention will apply to the U.S. partners whereas the interest article of the Canada-Germany Income Tax Agreement will apply to the German partners. ... Persons making payments to a partnership that includes both exempt and non-exempt U.S. partners which are the beneficial owners of the interest and dividends are advised to contact the Department in order to obtain assurance that their withholding obligations will, in respect of payments for such partners, be reduced to nil or 15% in accordance with the tax reduction provided for in the Convention. ...

Les conventions collectives actuellement en vigueur ont été conclues en XXXXXXXXXX et viendront à échéance le XXXXXXXXXX. 7. ... Chaque XXXXXXXXXX a établit une caisse XXXXXXXXXX (ci-après "Caiss "), conformément aux disposition des conventions collectives XXXXXXXXX, afin de comptabiliser les cotisations reçues des salariés en vertu de la clause XXXXXXXXXX de leur convention collective (ou l'équivalent de cette clause). 11. ... Ces séances visent principalement à permettre aux membres d'améliorer leurs connaissances dans différents aspects reliés aux relations du travail (par exemple, connaissance de leurs droits et obligations en vertu des conventions collectives). ...

XXXXXXXXXX is a wholly owned subsidiary of XXXXXXXXXX and was acquired by XXXXXXXXXX. is a corporation incorporated in The Netherlands on XXXXXXXXXX, and is resident in The Netherlands for purposes of the Canada-Netherlands Income Tax Convention (1986), as amended (the "Convention"). XXXXXXXXXX is wholly-owned by XXXXXXXXXX has its head office in XXXXXXXXXX does not carry on business in Canada nor does it have a permanent establishment in Canada for purposes of the Convention. 3. ... For the purposes of paragraph 4 of Article 13 of the Convention, the Canadian oil and gas properties owned by XXXXXXXXXX are property (other than rental property) in which the business of XXXXXXXXXX is carried on. ...

Finco wilt be resident in Australia for purposes of the Act and for purposes of the Canada-Australia Income Tax Convention (the "Convention"). ... The interest received by Finco from the Branch in respect of the Deposits will be exempt from Canadian withholding tax by virtue of the Convention. ... This ruling is based on the Act and the Convention in their present form and does not take into account any proposed amendments to the Act or the Convention which, if enacted into law, could have an effect on the ruling provided herein. ...

Principal Issues: Whether election by a UK corporation to have its shipping activities taxed under the new UK "tonnage tax" regime would cause it not to be a resident of the UK under the Canada-UK Income Tax Convention. ... The election by XXXXXXXXXX to be subject to the UK tonnage tax regime will not, in and by itself, preclude XXXXXXXXXX from being a resident of the UK for purposes of the UK Convention or preclude XXXXXXXXXX from being "resident in a designated treaty country" for purposes of Part LIX of the Regulations. ... This ruling is based on the Act and the UK Convention in their present form and does not take into account any proposed amendments to the Act or the UK Convention which, if enacted into law, could have an effect on the ruling provided herein. ...

(g) OPCO 3 is a XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. ... HOLDCO 7 is a XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. ... FINCO is an XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. ...

En XXXXXXXXXX, Commandité a conclu avec le Syndicat une convention (ci-après la " Convention Collective ") dans le but d'établir des relations satisfaisantes avec les employés syndiqués (ci-après les " Employés ") qui seront réembauchés par Commandité suite à la réouverture de l'Usine. ... L'Entente énonce les modalités de réintégration des Employés au travail et apporte quelques modifications à la Convention Collective. ... Commandité conclura une nouvelle convention pour assumer tous les droits et les obligations découlant de la Convention Collective et de l'Entente qui ont été transférés à Société en commandite tel qu'il est mentionné au paragraphe 11 précédemment. 17. ...

Principal Issues: Does paragraph 4 of Article XXVII of the Canada-UK Income Tax Convention apply to force Canada to treat such a transaction as a dividend in circumstances where we are not dealing with an ordinary dividend but instead a capital transaction. ... In this letter, the following terms have the meanings specified: (a)"adjusted cost base" ("ACB") has the meaning assigned to that term in section 54 of the Act; (b)"capital property" has the meaning assigned to that term in section 54 of the Act; (c)"Convention" means the Canada-United Kingdom Income Tax Convention (1978); (d)"foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; and (e)"UKCA" means the U.K.'s Companies Act (1985) and, where applicable, its predecessor statutes. ... B.Any withholding tax levied by the United Kingdom in accordance with paragraph 3(a)(ii) of Article X of the Convention on the aggregate of the amount considered a distribution under U.K. tax law and the Advance Corporation Tax Credit that XXXXXXXXXX is entitled to receive with respect thereto will be considered a non-business income tax as that term is defined in subsection 126(7) of the Act. ...

Income Tax Convention Reasons: (See detailed analysis below) XXXXXXXXXX XXXXXXXXXX 962059 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter of XXXXXXXXXX wherein you requested an advance ruling on behalf of XXXXXXXXXX. ... Income Tax Convention. This ruling is given subject to the limitations and qualifications set out in the Department's Information Circular 70-6R2 dated September 28, 1990, and Special Release relating thereto dated September 30, 1992. ... Income Tax Convention and should not be construed as having any impact on XXXXXXXXXX obligation to withhold under the ITA. ...

Our understanding of the facts, proposed transactions and purpose of the proposed transactions is as follows: FACTS 1.XXXXXXXXXX is a corporation resident in The Netherlands and a wholly-owned subsidiary of XXXXXXXXXX does not carry on business in Canada nor does it have a permanent establishment in Canada for purposes of the Convention. ... RULINGS GIVEN Provided that the above statements constitute a complete and accurate disclosure of all of the relevant facts, proposed transaction and purpose of the proposed transaction, and that the proposed transaction is carried out as set forth herein, the following rulings are given: A.For the purposes of paragraph 4 of Article 13 of the Convention, the XXXXXXXXXX are properties (other than rental properties) in which the business of the company is carried on and therefore do not constitute immovable property under paragraph 4(a) of Article 13. B.Where the greater part of the value of the shares of XXXXXXXXXX is derived from the XXXXXXXXXX any gain from the disposition of these shares by XXXXXXXXXX will be exempt from taxation in Canada pursuant to paragraph 4 of Article 13 of the Convention. ...