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(Tax Window, No. 13, p. 8, ¶1601)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 If a transfer out of a U.S. pension plan directly into an IRA would not have resulted in the amount being taxed in the U.S. had the person been resident there at the time of the transfer, the exemption of Article XVIII of the Canada-U.S. Convention will apply. ...

(Tax Window, No. 10, p. 23, ¶1483)-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 As "individual" is not defined in the Canada-Barbados Convention and as A.XVI(5) requires reference to domestic law for undefined words, "individual" includes a trust. ...

October 1992 T.I. 921009 "Loans to Non-Residents"-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Where a Canadian subsidiary issues a demand note to its U.S. parent, the deemed dividend arising under s. 214(3)(a) will be eligible for the reduced rate of withholding tax under Article X, paragraph 2(a) of the Canada-U.S. Convention. ...

(Tax Window, No. 17, p. 18, ¶1767)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 A retiring allowance is not periodic pension income and therefore is not eligible for rate reduction under Article XVIII, paragraph 2 of the Canada-U.S. Convention. ...

.-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A gain realized by the disposition by a U.S. resident of an interest in a partnership the value of which is not derived principally from real property situated in Canada will be exempt under paragraph 5 of Article XIII of the U.S. Convention. ...

TREATY PURPOSES-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 A payment under an unmatured RRSP is not considered to be a "pension" for purposes of paragraph 3 of Article 17 of the U.K. Convention because that amount will no longer fund any future entitlement under the RRSP. ...

CONVENTION-SHARE INCLUDES OPTION-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 "The reference in paragraph 3 of Article XIII [of the Canada-U.S. Convention] to 'a share of the capital stock of a company, the value of whose shares is derived principally from real property situated in Canada' includes an option in respect of such a share. ...

6 March 1995 Internal T.I. 9428767- VIDEO REPRODUCTION RIGHTS-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 The exemption in Article XII of the Canada-U.S. Convention for copyright royalties does not apply to royalties for video tape works intended for private (home) use. ...

3 December 1996 External T.I. 9636705- DEEMED GAINS AND ARTICLE XXII CAN/US TREATY-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Income resulting from the application of s. 107(5) is considered to arise in Canada and, therefore, is not exempt to a U.S. resident recipient under Article XXII of the U.S. Convention. ...

3 April 1995 External T.I. 9416455- S CORPS-LLC'S-RES OF A CONTRACTING STATE (HAA 4093 U5-100-4-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 An S corporation, unlike a limited liability company, is considered to be an entity resident in the U.S. under the Canada-U.S. Income Tax Convention. ...