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14 January 2009 External T.I. 2008-0274271E5 F- Rente de la Suisse-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 exemption under Art. 18(2) of the Canada-Switzerland treaty After noting that a Canadian resident receiving an old age pension from Switzerland could not avail of the exclusion in s. 56(1)(a)(i)(C.1) given the narrow scope of Reg.6803, CRA went on to note the exclusion for certain pensions (e.g., re Swiss government or military personnel, or alimony) in Art. 18(2) of the treaty with Switzerland. ...

17 February 1997 External T.I. 9617535- BARBADOS ENCLAVE ENTERPRISES-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 After indicating that the ten-year tax holiday for Barbados Enclave Enterprises does not, by itself, disqualify them from being considered as being resident in Barbados, RC indicated that the phrase "liable to taxation" refers to "full liability to tax", being the most comprehensive form of taxation of a person under the law of Barbados (i.e., taxation based on world income). ...

15 October 1997 External T.I. 9713855- ARTICLE XIII CANADA-ISRAEL TAX TREATY-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 alienation includes a deemed disposition under s. 128.1 Canada has the right to tax gains of a taxpayer from the deemed disposition of real property situate in Israel as a result of the taxpayer ceasing to be resident in Canada. ...

10 November 1997 External T.I. 9711175- FOREIGN AFFILIATES- INVESTMENT BUSINESS-- summary under Subsection 5907(11.2) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(11.2) A Barbados corporation that had International Business Corporation status in Barbados and that was ineligible for any tax benefit under the Canada-Barbados Income Tax Convention by virtue of Article XXX(3) thereof would qualify as a resident of a designated treaty country under Regulation 5907(11.2) if it was, in fact, liable to tax in Barbados on its worldwide income. ...

Limited Liability Company- Check-the-Box RULES-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 check-the-box corp a Treaty resident A U.S. ...

3 September 1997 Internal T.I. 9714337- STOCK OPTION BENEFIT EXERCISED BY A NON-RESIDENT-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 The benefit realized by a resident of the U.S. on the exercise of an employee stock option was not taxable in Canada because he was not present in Canada for more than 183 days in the year and the stock option benefit received by him was not deductible by the employer in computing its income. ...

29 July 1994 External T.I. 9418695- WITHHOLDING TAX COMPUTER SOFTWARE/SILDEN CASE-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Payments made by a Canadian resident to a U.S. resident for the right to distribute computer software would generally be taxable under s. 212(1)(d), but would not fall under the definition of royalties in Article 12 of the U.S. ...

12 April 1999 Income Tax Severed Letter 9812726- ARTICLE XXI CANADA-U.S. (4125-U5-100-21)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Before any consideration could be given to allowing an exemption for investment income paid to a U.S. master trust, the trust would be required to provide documentation that will clearly explain how it acted in trust for, or as agent for, the ultimate beneficial owners, the identity and residency of each beneficial owner, and the details of how the income was distributed to them. ...

Convention will not apply, s. 250(5) of the Act will not apply, the company will not be a foreign affiliate and will be taxed under the Act as a resident of Canada. ...

Convention will not apply, s. 250(5) of the Act will not apply, the company will not be a foreign affiliate and will be taxed under the Act as a resident of Canada. ...