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Income Tax Convention (Convention) Excess Amounts- Rate of Withholding Tax] September 9, 1987 Specialty Rulings Directorate K.B. ... Income Tax Convention (Convention) Excess Amounts- Rate of Withholding Tax This is in reply to your memorandum of August 25, 1987 concerning the treatment of "excess interest" and "excess royalties" referred to in paragraph 7 of articles XI and XII of the Convention. In order to determine the treatment of the excess interest and royalties under the Convention the above articles clearly indicate in paragraph 7 that the "...excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of the Convention." ...

Income Tax Convention (Convention)] DATE. January 5, 1988 TO- International Audit Division J.A. ... Income Tax Convention (Convention) This is in reply to your memorandum of November 16, 1987 concerning the treatment of recapture of capital cost allowance under the Convention. It continues to be our general view, for the reasons set out in the letters attached to your memorandum, that Article XIII of the Convention will have application to capital gains derived by a resident of the United States whereas Articles VI, VII, VIII and XIV of that Convention will apply to tax the income, including the recapture of capital cost allowance, which a non-resident earns in Canada. ...

12 April 1988 Income Tax Severed Letter 5-5390- [Foreign Pension Income Canada-Italy Income Tax Convention (the "Convention")] T.B. Kuss (613)957-2128 April 12, 1988 Dear Sirs: Re: Foreign Pension Income Canada-Italy Income Tax Convention (the "Convention") This is in response to your letter dated January 18, 1988 regarding the above-referenced subject. Specifically you have asked for our comments on the interaction of paragraph 2 of Article XVIII of the Convention and paragraphs 60(j) and 110(1)(f) of the Income Tax Act (the "Act"). ...

Income Tax Convention (1980) (the "Convention")] Revenue Canada Taxation Head Office TO- International Audits Division David Burton FROM- Specialty Rulings Directorate O.S. ... Income Tax Convention (1980) (the "Convention") This is in response to your memorandum of June 27, 1988. ... Corporation, the Internal Revenue Code will permit postponement of the recognition of both the gain on disposition of shares by an individual and on the distribution of assets by that corporation, it is our view that such a transaction would fall with the ambit of Article XIII(8) of the Convention. ...

9 January 1989 Income Tax Severed Letter 7-3368 F- [Convention fiscale entre le Canada et la France (la "Convention") Employés dispensés d'activité] Jan 9 1989 À Divison des relations provinciales et internationales R.G. D'Aurelio Directeur DE Section des services bilingues Charles Théiault 957-8981 OBJET: Convention fiscale entre le Canada et la France (la "Convention") Employés dispensés d'activité La présente note de service est en réponse à la vôtre du 24 août 1988 dans laquelle vous demandez notre opinion concernant l'application de la Convention dans la situation suivante: Une société française a conclu un accord avec des organisations syndicales représentatives de son personnel. ... Vous désirez savoir si c'est l'article XV ou l'article XVIII de la Convention qui devrait s'appliquer aux paiements faits pendant une période dispensée d'activité. ...

Income Tax Convention, 1980 (the "Convention")] Revenue Canada Taxation Head Office XXXX T.B. ... Income Tax Convention, 1980 (the "Convention") This is in response to your letter dated October 24, 1988 in which you requested a technical interpretation of the above- referenced provisions of the Convention. ...

Income Tax Convention, 1980 (the "Convention")] T.B. Kuss (613) 957-2120 July 22, 1987 Dear Sirs: Re: Articles IV and XXI of the Canada-U.S. Income Tax Convention, 1980 (the "Convention") This is in reply to your letter of July 2, 1987 regarding the above- referenced subject. ...

25 March 1991 Income Tax Severed Letter 910104- [Article XIII(9) of the Canada-United States Income Tax Convention, 1980 (the "Convention")] Revenue Canada Taxation Head Office G. Arsenault (613) 957-2126 Attention XXXX Mar 25 1991 Dear Sirs: Re: Article XIII(9) of the Canada-United States Income Tax Convention, 1980 (the "Convention") This is in reply to your letter dated January 11, 1991 whereby you requested our views concerning whether a farm owned by a resident of the United States would constitute "an asset that on September 30, 1980 formed part of the business property of a permanent establishment situated in [Canada]" within the meaning of subparagraph (c) of paragraph 9 of Article XIII of the Convention. ... Paragraph 1 of Article V of the Convention expressly recognizes that a person may have a permanent establishment in a Contracting State where the business is only partly carried on. ...

Income Tax Convention (1980) (the “new treaty”) vs. Canada-U.S. Income Tax Convention (1942) (the “old treaty”) Unedited CRA Tags none This is in response to your memorandum of June 9, 1989. ...