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Income Tax Convention- U.S. Estate Tax Unedited CRA Tags n/a 24(1) 902998   G. Arsenault   (613) 957-2126 19(1) December 10, 1990 Re:  Canada-United States income Tax Convention, 1980 (the "Convention")- U.S. ... It is our understanding that United States estate tax is not a tax on capital and that Article XXIII of the Convention is not applicable thereto. ...

1 October 1990 Ministerial Letter 901828 F- Canada-Japan Income Tax Convention on Capital Gains Unedited CRA Tags n/a 24(1) 901828   G. Arsenault   (613) 957-2126 19(1) October 1, 1990 Dear Madam: Re:  Canada-Japan Income Tax Convention (1986) (the "Convention") This is in reply to your letter dated August 3, 1990. In our opinion, residents of Japan are not granted any exemption from Canadian tax on capital gains by the Convention. ...

13 November 1990 Ministerial Letter 901998 F- Canada-Italy Tax Convention Unedited CRA Tags 217, 110(1)(f)(i)   November 13, 1990 WINDSOR DISTRICT OFFICE HEAD OFFICE P. ... Biscaro   (613) 957-2122 Attention: Edward Hooft International Audit 901998 SUBJECT:  Canada-Italy Tax Convention (the "Convention") We have been asked to reply to your memorandum of July 24, 1990 to Christine Savage, Acting Director, Provincial and International Relations Division concerning Article XVIII of the Convention which deals with pension receipts. ... With respect to the Canada-Italy Convention, the legislators effectively wrote the elective provisions of section 217 of the Act into paragraph 1(b) of Article XVIII of the Convention for purposes of determining the applicable tax rate. ...

Income Tax Convention on Capital Gains Unedited CRA Tags 48(1)(c), 48(2), 54 capital property, 115(1)(b)(ix), 126(2.2) 24(1) 5-9618   S. ... Tax Convention (1978) (the "Convention"). An individual (the "taxpayer"), formerly resident in Canada owned real estate property (the "real property") located in the United Kingdom (the "UK").  ... This type of problem may have to be resolved through the competent authority procedures set out in Article VIII of the Convention. ...

25 February 1991 Ministerial Letter 910498 F- Convention Expenses Unedited CRA Tags 20(10) Re:  Convention Expenses Thank you for your letter of February 8, 1991.  ... You have queried the deductibility of convention expenses to be incurred by 24(1) The deductibility for income tax purposes of convention expenses depends upon each individual's particular set of circumstances and can be determined only after his or her income tax return is filed and all relevant facts determined.  ... Subsection 20(10) of the Income Tax Act permits a deduction in respect of expenses incurred in attending not more than two conventions per year for taxpayers who are carrying on a business.  ...

31 August 1989 Ministerial Letter 57778 F- Canada–Israel Income Tax Convention Unedited CRA Tags 116 19(1) File No. 5-7778   D.Y. Dalphy   (613) 957-2117 August 31, 1989 Dear Sirs: Re:  Disposition of Shares By a Non-Resident Article XIII of the Canada-Israel Income Tax Convention, 1976 This is in reply to your letter of March 20, 1989 wherein you requested our interpretation of Article XIII of the Canada-Israel Income Tax Convention, 1976 (the "Treaty"). ...

Income Tax Convention- Distribution of Partnership Assets Unedited CRA Tags n/a 19(1) File No. 5-8738   K.B. ... Income Tax Convention (1980)(the "Convention"). Your letter stated that you are concerned with a situation where a U.S. partnership distributes its assets to its partners, one or more (but not the majority) of whom are Canadian partners.  ... Income Tax Convention (the "Convention") provides that where a resident of a Contracting State alienates property in the course of a corporate organization, reorganization, etc., the profit, gain or income in respect of such alienation may be deferred in order to avoid double taxation.  ...

Campbell This is in reply to your letter of March 29, 1989 concerning paragraph 2(d)(i) of Article 23 of the Canada-Sweden Income Tax Convention (1983) (the "Convention"). ... The issue is whether the dividend payment to Sweden from the NRO is exempt from Swedish tax under paragraph 2(d)(i) of Article 23 of the Convention. ... Based on our interpretation of the Article and the intention of the Convention, we are of the view that a dividend from the NRO to Swedenco in the situation set out in paragraph 2 above would probably not be exempt, by virtue of paragraph 2(d)(i) of Article 23 of the Convention, from Swedish tax.  ...

Income Tax Convention in support of his request for the remission of the tax liability on the gain.     ... Income Tax Convention, and also, the foreign merger provisions of subsection 87(8) of the Canadian Income Tax Act. ... In the case of Article XIII(8) of the Convention, where a reorganization is afforded, tax free treatment in the taxpayer's country of residence, the competent authorities under the Convention may provide for deferral of tax under the laws of the other country in order to avoid double taxation. ...

4 January 1990 Ministerial Letter 90M01068- Convention fiscale avec la France- demande de renseignements Unedited CRA Tags n/a 19(1) E.E. ... Cette demande est présentée en vertu de l'article 25 de la Convention entre le Canada et la France en matière d'impôts sur le revenu. ...