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2 February 2005 External T.I. 2004-0104671E5 F - Convention de retraite - Fonds mis de côté -- summary under Retirement Compensation Arrangement

2 February 2005 External T.I. 2004-0104671E5 F- Convention de retraite- Fonds mis de côté-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement no requirement that payment to the other be in trust In a general response to a query as to whether a special reserve fund that an employer creates by depositing money with a broker to provide for the payment of a portion of a pension payable for the retirement of a management employee will constitute a salary deferral arrangement or a retirement compensation arrangement, CRA stated: In a situation where an employer pays money to a bank, trust company or broker to meet its obligations upon the retirement of an employee, the money could be considered a contribution in respect of benefits that may be received by a person upon that person's retirement. … Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Refundable Tax

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Refundable Tax Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax use of letter of credit to secure RCA benefits The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ...

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Subsection 207.5(2)

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Subsection 207.5(2) Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(2) election not available to custodian holding an LC The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ...

29 May 2007 Internal T.I. 2006-0217401I7 F - 110(1)d): Moment de la conclusion de la convention -- summary under Subsection 7(5)

29 May 2007 Internal T.I. 2006-0217401I7 F- 110(1)d): Moment de la conclusion de la convention-- summary under Subsection 7(5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(5) not giving exercise notice to employees who are not shareholders (so that they cannot exercise their options) may engage s. 7(5) Employees of Opco (Participants”) were granted stock options by Opco pursuant to “Grant Agreements” which specified the number of Options granted and their exercise price (which equaled the FMV of the subject shares at the time of such grant), but provided that such Options were not exercisable (and could not be surrendered to Opco for their cash surrender value) until the compensation committee of Opco had issued an “Exercise Notice” to the Participant. ...

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Subsection 207.7(2)

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Subsection 207.7(2) Summary Under Tax Topics- Income Tax Act- Section 207.7- Subsection 207.7(2) where LC used to secure RCA benefits and refundable tax generated on funding of LC fees, refundable tax not recoverable based on paying the benefits The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ...

10 January 1990 Income Tax Severed Letter 7-4446 - [Article XIII of the Canada-U.S. Income Tax Convention (the "Convention")]

Income Tax Convention (the "Convention")] Revenue Canada Taxation MEMORANDUM TO/A Non-Resident Taxation Division FROM/DE Specialty Ruling Directorate K.B. ... Income Tax Convention (the "Convention") This is in reply to your memorandum of October 19, 1989 concerning what is meant by the term "gain which is liable to tax in that other State" in paragraph 9 of Article XIII of the Convention. ... Article III of the Convention provides a definition of many terms used in the Convention, however, the article does not define the term "gain" for purposes of the Convention. ...

20 November 1989 Income Tax Severed Letter 5-8666 - [Article XIII of the Canada-U.S. Income Tax Convention (1980) (the "1980 Convention")]

Income Tax Convention (1980) (the "1980 Convention")] Revenue Canada Taxation Head Office O. ... Income Tax Convention (1980) (the "1980 Convention") This is in response to your letter of September 7, 1989, wherein you have asked us to interpret the transitional provisions set out in paragraph 9 of Article XIII of the 1980 Convention, as they apply to a disposition by a U.S. resident of taxable Canadian property that had been acquired prior to December 31, 1971 ("V-day"). In our view the intent of paragraph 9 of Article XIII of the 1980 Convention was to effect a transition between the status of United States resident under the 1942 Convention and his status under the 1980 Convention. ...

5 September 1989 Income Tax Severed Letter 7-4083 - [Paragraph 3 and 4 of Article XIII of the Canada-U.S. Income Tax Convention (the \"Convention\")]

Income Tax Convention (the \"Convention\")] Unedited CRA Tags none This is in reply to your memorandum of June 27, 1989 wherein you requested our opinion concerning the treatment of capital gains arising from the disposition of real property under Article XIII of the Convention. Subparagraph (b)(i) of paragraph 3 of Article XIII of the Convention states that real property means "(r)eal property referred to in Article VI situated in Canada". ... In our opinion paragraph 3 of Article XIII of the Convention was intended to- tax capital gains on the disposition of shares of the capital stock of a company, the value of which is derived principally from real property as that term is defined in the Convention (i.e. including not only real property as defined in Article VI of the Convention but also shares of the capital stock of other corporations or an interest in a partnership, trust or estate which is real property as defined in subparagraph 3(b) of Article XIII of the Convention). ...

16 June 1987 Income Tax Severed Letter 5-3282 - [ Technical Interpretation requested concerning certain provisions of the Income Tax Act (the "Act") and the Canada United Kingdom Income Tax Convention (1978) (the "Convention")]

16 June 1987 Income Tax Severed Letter 5-3282- [Technical Interpretation requested concerning certain provisions of the Income Tax Act (the "Act") and the Canada United Kingdom Income Tax Convention (1978) (the "Convention")] June 16, 1987 A.A. ... Canco does not have a "permanent establishment" in Canada, as that term is defined in Article 5 of the Convention. ... In most cases, however, questions of residency involving a specific corporation otherwise resident for the purposes of the Convention in both Contracting States due to the provisions of paragraph 1 of Article IV of the Convention would be raised by that corporation as it would likely be enduring double taxation. 2. ...

29 August 1988 Income Tax Severed Letter 5-6077 - [Canada-Brazil Income Tax Convention (the "Convention")]

29 August 1988 Income Tax Severed Letter 5-6077- [Canada-Brazil Income Tax Convention (the "Convention")] 144A.03 O.S. Laurikainen (613) 957-2125 AUG 29 1988 Dear Sir: Re: Canada-Brazil Income Tax Convention (the "Convention") This is in response to your letter of May 17, 1988 wherein you have made enquiries concerning the application of Articles 10 and 22 of the above Convention. ... Since this definition of the term "equity percentage" is found in Canadian tax law, we are unable to comment on whether this same meaning would be employed by Brazilian authorities in interpreting the Convention. ...

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