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Position: The trust was a resident of the United States for the purposes of the Convention. ... Income Tax Convention (1980) (the "Convention"). 6. Canco, Opco and Otherco are corporations incorporated and resident in Canada. 7. ... It is unlikely in such case that the Convention would exempt such gain. ...

2007 Ruling 2005-0149681R3- Article XXI of Canada-US Tax Convention Unedited CRA Tags Article XXI Canada-US Tax Convention Principal Issues: Will the non-resident corporation carry on a business in Canada for the purposes of paragraph 3 of Article XXI of the Canada-US Tax Convention? ... The above rulings are based on the Act and the Tax Convention in their present form and do not take into account any proposed amendments to the Act or Tax Convention. ... OPINION The word "income" is not defined in the Tax Convention or in the Income Tax Act. ...

24 April 1990 Ruling HBW84131/4125J1 (E) F- Canada-Japan Income Tax Convention on Employment Income Unedited CRA Tags n/a 19(1) B. ... As a continuing resident of Canada, any employment income earned outside the JET Programme is subject to income tax in Canada pursuant to Article 15 of the Canada-Japan Income Tax Convention. ... Participants in the JET Programme are governed by Article 18 of the Convention and are exempt from tax in Canada based on the unique nature of the Programme.  ...

5 October 1989 Ruling HBW41253 F- Canada-Austria Income Tax Convention Unedited CRA Tags n/a 19(1) David R. ... Pursuant to paragraph 3 of article XXV of the Canada-Austria Income Tax Convention (1976) and in our capacity as Canadian competent authority we wish to confirm our agreement with the following interpretation of Article XIX of the said Convention. ...

15 February 1990 Ruling HBW4125U31A F- Canada-US Income Tax Convention- Interest Income Exemption Unedited CRA Tags Can. ... Pursuant to Article XI, subparagraph 3(a) of the Canada-United States Income Tax Convention, interest income arising in Canada and paid to the corporation is exempt from tax in Canada.  ... In the event of a change in status of the Corporation or an amendment or repeal to Article XI of the Convention (i.e. ...

Principal Issues: Application of Article XVI(4) of the Canada-U.S Tax Convention. ... The Player is a resident of the United States and is not a resident of Canada for purposes of the Act or the Convention. 7. ... Provided that the Player is a resident of the U.S. for the purpose of the Convention at the time an amount in respect of the Signing Bonus is paid to the Player, such amount will be eligible for treatment under paragraph 4 of Article XVI of the Convention, with the result that the gross amount of the Signing Bonus will be subject to tax under Part I of the Act at a rate not to exceed 15%. ...

You describe the facts as follows: 24(1) 24(1) You have concluded that the payments in question, given that they are taxable pursuant to paragraph 6(1)(f) of the Act, are also taxable under Article XV of the Canada-Philippines Income Tax Convention (the Convention). ... In regard to the Convention, it is our opinion that the exemption from Canadian taxation provided therein pursuant to paragraph 2 of Article XV thereof does not apply. ... In addition, paragraph 2 of Article XV of the Convention does not apply to exempt the disability payments to the non- resident individual from taxation in Canada. ...

2007 Ruling 2007-0248021R3- Cdn Japan Convention: withholding rate deemed div. ... The Company is a resident of Japan for purposes of the Act and the Convention. ... The deemed dividend arising under subsection 84(3) of the Act on the purchase for cancellation of the Shares will be subject to tax at a rate of 5% of the gross amount of the dividend pursuant to subsection 212(2) of the Act and Article 10 of the Convention. ...

Convention? 2)Can Estate deduct income attributable to net taxable capital gains under 104(6)(b)? ... XXXXXXXXXX 6.The Beneficiary attained XXXXXXXXXX. 7.The Beneficiary is a citizen and resident of the United States for purposes of the Canada- United States Income Tax Convention 1980 (the "Convention"). 8.The Beneficiary is XXXXXXXXXX and therefore an exempt beneficiary. 9.The Estate's assets consist primarily of shares of U.S. corporations traded on stock exchanges in the U.S. and denominated in U.S. dollars (the U.S. ... Securities it will be exempt from Part XIII tax pursuant to paragraph 2 of Article XXII of the Convention. ...

30 January 1990 Ruling HBW6591A1 F- Canada-Australia Income Tax Convention Unedited CRA Tags Canada/Australia Treaty Art. 25 19(1) HBW 6591-A1   Al Watson   (613) 957-2072 Attention: January 30, 1990 Dear Sir: We have received the attached material that was requested from the Western Regional Office, Operations.  The attached material is being provided pursuant to Article 25 of the Convention between Canada and Australia. ...