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Pubco is a resident of the United States for the purposes of the Convention and is a "qualifying person" as described in Article XXIX-A(2)(c) of the Convention. 6. ... US Holdco will be entitled to the same benefits under Article X(2) of the Convention that it would be entitled to if a dividend referred to in Ruling A or B were paid as a cash dividend and the Convention were read without reference to Article IV(7)(b). ... The above-noted rulings are based on the Act and the Convention in their present form and do not take into account any proposed amendments to the Act or the Convention which, if enacted, could have an effect on the rulings provided herein. ...

GP is a resident of the United States for the purposes of the Convention. 5. ... Canco is a resident of Canada for the purposes of the Convention. Canco is disregarded as an entity separate from its owner under the Code and is fiscally transparent under the taxation laws of the United States for the purposes of the Convention. 9. ... The above-noted rulings are based on the Act and the Convention in their present forms and do not take into account any proposed amendments to the Act or the Convention which, if enacted, could have an effect on the rulings provided herein. ...

X will be resident in France under the Canada-France Tax Convention (the "Convention") and will not be subject to Canadian tax on his salary from the XXXXXXXXXX is a condition precedent for Mr. ... X is a resident of France under the provisions of paragraph 1 of Article 4 of the Convention, by virtue of paragraph 2 of Article 4 of the Convention, Mr. ... X is a resident of France under the provisions of paragraph 1 of Article 4 of the Convention, by virtue of paragraph 2 of Article 4 of the Convention, Ms. ...

(e) "Convention" means the Canada-United States Income Tax Convention (1980), as amended by subsequent protocols to the date hereof. ... The members of LLC are comprised solely of individuals that are resident in the United States for the purposes of the Convention. 4. ... LLC is a resident of the United States for purposes of the Convention. ...

Income Tax Convention the rate is reduced to 10 per cent of the gross amount of the royalties in accordance with paragraph 2 of Article XII. ... If the non-resident payee is considered to be a resident of the U.S. for purposes of the Convention, such payee will be exempt under Article VII of the Convention, from Canadian tax on the business profits earned from the provisions of the services unless the payee carries on business in Canada through a permanent establishment in Canada and the profits are attributable to such permanent establishment. A payee who is exempt from Canadian taxation by virtue of Article VII of the Convention may obtain a refund of taxes withheld under Regulation 105(1) by filing a Canadian tax return (note that Article VII in the Convention does not prohibit the initial withholding under Regulation 105(1) but does entitle a payee who is exempt thereunder from Canadian tax to obtain a refund of amounts so withheld). ...

Les conditions de travail des Employés sont présentement régies par l’Ancienne Convention Collective. Employeur et Syndicat sont présentement en négociations collectives dans l’objectif de conclure la Convention Collective. ... Employeur et Syndicat souhaitent de concert intégrer le Régime à la Convention Collective afin qu’il puisse être offert à tous les Employés Admissibles. 5. ...

Income Tax Convention (the "Convention") in accordance with Article IV of the Convention ("U.S. ... Pension Fund, Master Trust or Charitable Organization which is constituted in the United States will pursuant to subparagraph (1)(b) of Article IV of the Convention, be considered to be a resident of the United States for the purposes of the Convention. ... E.Provided that a U.S. investor that acquires units of the Fund or a U.S. investor who is a member of a partnership that acquires units of the Fund, did not become a resident of the United States for the purpose of obtaining the benefits of the Convention and can reasonably be considered the beneficial owner of the income distributed by the Fund, the benefits of the Convention will not be denied to the investor as contemplated by paragraph 7 of Article XXIXA of the Convention. ...

Income Tax Convention? Position: Yes. Reasons: Leasehold interest in a land situated in Canada is an interest in a real property and a real property situated in Canada. ... M-A and M-B are non-residents of Canada and are residents of the United States for purposes of the Act and the Convention. ... For the purposes of paragraph 3(b)(ii) of Article XIII of the Convention, the permit, as described in paragraph 10 herein, does not represent a real property situated in Canada. ...

Position: The taxable capital gain on the dispositions of TCP will be exempt from tax by virtue of paragraph 5 of Article 13 of the German Convention. ... Thus, paragraph 4 of Article 13 of the German Convention does not apply to the dispositions. Since the gains, if any, from the dispositions of TCP do not fall under paragraphs 1 to 4 of Article 13 of the German Convention, such gains are exempt from tax in Canada by virtue of paragraph 5 of Article 13 of the German Convention. ...

Income Tax Convention (1980) apply to the Fund where it pays income to U.S. residents? ... Income Tax Convention (1980) (the "Convention") will be exempt from withholding tax under paragraph 212(1)(c) of the Act pursuant to paragraph 2 of Article XXII of the Convention where the income is derived from sources outside Canada Raisons POUR POSITION ADOPTÉE: Technical notes on Article XXII, paragraph 2 of the Convention and CCM #3-952708 and 3-963582 and 5-941261 XXXXXXXXXX 3-972299 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your request of XXXXXXXXXX and your subsequent correspondence in which you requested an advance income tax ruling on behalf of XXXXXXXXXX, in respect of the tax consequences under the Income Tax Act (Canada) (the "Act") resulting from distributions made by the Fund to U.S. resident unitholders as described below. ... Income Tax Convention (1980) (the "Convention"), will be exempt from withholding tax under paragraph 212(1)(c) pursuant to paragraph 2 of Article XXII of the Convention where the income is derived from sources outside Canada and the provisions of section 215 will not apply in respect of such distribution of income. ...