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20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)-- summary under Rules Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27A- Rules A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to English estate duty to a deemed disposition under s. 70(5) on shares of a private Canadian corporation and would not be considered to be taxed in the U.K. by reference to an amount that was remitted to or received in the U.K. as a result of such deemed disposition. ... Convention would not apply. ...

20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to English estate duty to a deemed disposition under s. 70(5) on shares of a private Canadian corporation and would not be considered to be taxed in the U.K. by reference to an amount that was remitted to or received in the U.K. as a result of such deemed disposition. ... Convention would not apply. ...

6 November 1992 T.I. 922332 (September 1993 Access Letter, p. 425, ¶C248-142)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Where a Canadian employee of a U.S. company was a deemed resident of Canada under s. 250(1)(a) but was a U.S. resident under the tie-breaker rule in paragraph 2 of Article IV of the Canada-U.S. Convention, interest or dividends received from a U.S. resident or from a third country would be taxed only in the U.S. by virtue of paragraph 1 of Article XXII. ...

(Tax Window, No. 2, p. 28, ¶1216)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Exempt organizations created in a country with which Canada has a tax treaty are residents of that contracting state for treaty purposes and are therefore entitled to the same benefits as those provided under a tax treaty to other residents of that state. ... Convention, which is resident in the United States, will be exempt from Canadian tax by virtue of that paragraph provided that Article XXI(3) does not apply. ...

8 April 1992 T.I. (913412 (March 1993 Access Letter, p. 83, ¶C180-135; Tax Window, No. 18, p. 10, ¶1847)-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Where s. 214(3)(a) imputes a shareholder benefit to U.S. resident shareholders of a U.S. corporation which allows them to use a Canadian vacation property free of rent, Article X(5) of the Canada-U.S. Convention will not grant relief to them because s. 214(3)(a) deems the dividend to have been paid by a corporation resident in Canada rather than by a U.S. corporation. ...

"Non-Resident Exercise Stock Option (4093-U5-100-15)")-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 A detailed example showing how a stock option benefit ultimately realized by a U.S. ... Convention is then applied on a year-by-year basis. Accordingly, the individual is exempt where in a year he was present in Canada for less than 183 days, or the total remuneration for that year, including the portion of the stock option benefit allocated to that year, is less than Cdn. $10,000. ...

25 June 2012 External T.I. 2011-0404071E5- Election to defer income in U.S. traditional IRA-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 It is unnecessary for a Canadian-resident individual to file an election under Art. XVIII(7) of the Canada-US Convention to defer recognition of income on investments in a US Individual Retirement Account because the Act already provides such deferral: Under clause 56(1)(a)(i)(C.1) of the Act, an individual is required to include amounts under a foreign retirement arrangement in income only when the amounts are paid out of the plan. ...

17 February 1997 External T.I. 9625935- SOURCE OF CANADIAN TRUST INCOME RE ART XXI(6)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Where a trust resident in Canada has made a designation under s. 104(22) with respect to U.S. ... Convention, given that s. 104(22) recharacterizes the income only for limited purposes. ...

11 October 1996 APFF Roundtable, 7M12910- APFF ROUND TABLE-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Where specific anti-avoidance provisions are not applicable to a transaction or series of transactions that results in tax abuse, the general anti-avoidance provision may be applied even before taking tax conventions into account. ... Convention. ...

TREATY-- summary under Rules Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27A- Rules Re application of paragraph 4 of Article 27 of the Canada-U.K. Convention where a share of a U.K. corporation held by a resident of Canada is purchased for cancellation. ...