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In order for it to fall within the jurisdiction of Article XIX of the Canada-Belgium Income Tax Convention (1975) (the "treaty") however, remuneration earned by an individual has to be in respect of services rendered by him to the government of Canada. ...

The agreement did not cover withholding rates or contain many other details which more modern tax conventions have. ...

Income Tax Convention (1980) (the "Treaty") has a tie-breaker rule that provides that a company resident in both countries, would be resident in the country in which it was created (incorporated) for the purposes of the treaty 24(1) subsection 250(5) would have deemed 24(1) to also be a non-resident of Canada for the purposes of the Act. 24(1) 24(1) Date of Disposition of the Shares of 24(1) 24(1) 24(1) Number of Shareholders 24(1) 24(1) In any case, an assessment of the gain as FAPI may reduce or virtually eliminate any Canadian tax benefit the taxpayers may have otherwise enjoyed by virtue of having 24(1) for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch ...

Article 13 of the Canada-Germany Income Tax Convention will override our domestic laws (as described in 1 through 4) where the non-resident disposes of taxable Canadian property that is neither immovable property nor shares forming part of a substantial interest in the capital stock of a company of which is a resident of Canada the value of which shares is derived principally from immovable property situated in Canada.  ...

OPCO, PORTCO1, PORTCO2 et PORTCO3 ont conclu une convention entre actionnaires le XXXXXXXXXX, laquelle est encore en vigueur. La convention est une convention unanime des actionnaires XXXXXXXXXX. 8. ... La politique de dividendes de OPCO est fondée sur XXXXXXXXXX la convention entre actionnaires du XXXXXXXXXX. ...

Selon une convention de licence (ci-après la " Convention ") originalement intervenue entre MÈRECO et OPCO en XXXXXXXXXX, MÈRECO a accordé à OPCO, en échange d'une redevance annuelle de XXXXXXXXXX $, les droits et licences d'utilisation des Marques de Commerce détenues par MÈRECO qui sont utilisées dans l'entreprise d'OPCO. ... OPCO peut, en vertu de cette Convention, exercer son entreprise sans contrainte XXXXXXXXXX. ... Une convention de crédit a été conclue entre OPCO, MÈRECO, PORTCO et XXXXXXXXXX institutions financières. ...

The charter may cover varying periods of time and a daily or monthly fixed rate is paid for the charter; (l) "Agreement" means the Bareboat Charter Agreement entered into by Partnership IX and Foreign Co; (m) "Canada" means Canada as defined in section 5 of the Income Tax Conventions Interpretation Act, R.S.C. 1985, c. I-4, as amended to the date hereof; (n) "Contract" means the Time Charter Agreement entered into by Foreign Co and the Cancos; (o) "CRA" means the Canada Revenue Agency; (p) "Foreign Country" means Norway; (q) XXXXXXXXXX (r) "Payments" means the payments to be made by Foreign Co to Partnership IX under the terms the Agreement; (s) "Province" means the province of XXXXXXXXXX; (t) "Ship" means the XXXXXXXXXX; (u) "Treaty" means the Canada-Norway Tax Convention which entered into force on December 19, 2002; (v) "arm's length" has the meaning assigned by subsection 251(1) of the Act; (w) "public corporation" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act; and (x) "taxable Canadian corporation" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act. ...

2014 Ruling 2014-0527221R3- Disposition of shares under Canada-Israel Treaty CRA Tags Treaties Article XIII 2(3)(c) 248 Principal Issues: Whether a gain realized by a company resident in Israel on the disposition of shares of a Canadian corporation, in a situation where the Canadian corporation holds shares of another Canadian corporation and the shares of that other Canadian corporation derive their value principally from real or immovable property situated in Canada, will be exempt from Canadian tax under the Act by virtue of paragraph 4 of Article XIII of the Canada-Israel Tax Convention. ... (a) "Canadian partnership" has the meaning assigned by subsection 102(1) of the Act; (b) "Canco1" means XXXXXXXXXX; (c) "Canco2" means XXXXXXXXXX; (d) "Dispositions" means the disposition of the shares of Canco2 by Foreign Holdco and the disposition of the shares of Canco1 by Foreign Parent described in the Proposed Transactions; (e) "Exchange" means the XXXXXXXXXX; (f) "Foreign Holdco" means XXXXXXXXXX; (g) "Foreign Parent" means XXXXXXXXXX; (h) "Foreign Parent Companies" means Foreign Parent and Foreign Holdco; (i) "Income Tax Ordinance" means the legislative act codifying the Israeli income tax law; (j) "LP" means XXXXXXXXXX; (k) "Other Exchanges" means XXXXXXXXXX and XXXXXXXXXX; (l) "Proposed Transactions" means the transactions described in paragraphs 8 and 9 below; (m) "Pubco" means XXXXXXXXXX; (n) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; and (o) "Treaty" means the Convention between Canada and the Government of the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, signed on July 21, 1975 and entered into force on July 27, 1976. ...

For greater certainty, nothing in this advance income tax ruling should be construed as implying that the CRA has agreed to or reviewed the determination of: (a) the fair market value of any property described herein; (b) whether an Investor is resident in a particular country; (c) whether the result obtained by an Investor is not consistent with the scheme of Treaty 1, Treaty 2, Treaty 3 and/or Treaty 4 such that the proposed transactions would result in an abuse of a treaty to which subsection 245(2) of the Act would apply to re-determine the tax consequences to an Investor; or (d) the mode of application of Article 13 of any convention, within the meaning of section 2 of the Income Tax Conventions Interpretation Act, not described in Rulings B through F. ...

Canco' Business Number is XXXXXXXXXX, and Canco files its corporate tax returns with the XXXXXXXXXX Tax Centre, and is served by the XXXXXXXXXX TSO; (c) "controlled foreign affiliate" has the meaning assigned by subsection 95(1); (d) "CRA" means the Canada Revenue Agency; (e) "Dco" means XXXXXXXXXX; (f) "DCO Treaty" means the Convention Between Canada and XXXXXXXXXX; (g) "FAPI" means "foreign accrual property income" as that term is defined in subsection 95(1); (h) "foreign accrual tax" has the meaning assigned by subsection 95(1); (i) "foreign affiliate" has the meaning assigned by subsection 95(1); (j) "Gco" means XXXXXXXXXX; (k) "G Holdings" means XXXXXXXXXX; (l) "GCO Loan" means the interest-bearing loan to be made by US LLC to Gco, as described in paragraph 9; (m) "GCO Treaty" means the Agreement Between Canada and XXXXXXXXXX; (n) "non-resident" has the meaning assigned by subsection 248(1); (o) "Paragraph" means a numbered paragraph in this letter; (p) "Pubco" means XXXXXXXXXX, a corporation formed under the laws of the State of XXXXXXXXXX; (q) "Pubco Group" is described in Paragraph 1 below; (r) "Regulations" means the Income Tax Regulations; (s) "taxable Canadian corporation" has, by virtue of subsection 248(1), the meaning assigned by subsection 89(1); (t) "United States" means the United States of America; (u) "US LLC" means a limited liability company to be formed under the laws of the State of XXXXXXXXXX; (v) "US Sub" means XXXXXXXXXX, a corporation formed under the laws of the State of XXXXXXXXXX; and (w) "US Treaty" means the Convention between Canada and the United States of America With Respect to Taxes on Income and Capital Signed on September 26, 1980 as Amended by the Protocols Signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007. ...