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Current CRA website
Required Withholding from Amounts Paid to Non-Residents Providing Services in Canada
This submission must provide information as to the applicability of the treaty article of the income tax convention of the country of residence of the employee. ... Article XV of the 1980 Canada-United States Income Tax Convention (the Convention) is used for illustrative purposes. ¶ 92. ... Income tax conventions or treaties ¶ 98. Canada reserves the right to tax income earned within its boundaries. ...
Current CRA website
Required Withholding from Amounts Paid to Non-Residents Providing Services in Canada
This submission must provide information as to the applicability of the treaty article of the income tax convention of the country of residence of the employee. ... Article XV of the 1980 Canada-United States Income Tax Convention (the Convention) is used for illustrative purposes. ¶ 92. ... Income tax conventions or treaties ¶ 98. Canada reserves the right to tax income earned within its boundaries. ...
Current CRA website
Income Tax Audit Manual
Tax conventions are a bridge between two independent taxing systems. Each taxing system is developed independently for internal legal purposes. ... The terms “tax treaty” and “tax convention” mean the same thing. A protocol is simply an addition to an existing treaty. ... Notwithstanding the provisions of a convention or the Act giving the convention the force of law in Canada, it is hereby declared that the law of Canada is that, to the extent that a term in the convention is (a) not defined in the convention. ...
Current CRA website
When to register for and start charging the GST/HST
You sponsor (host) a convention in Canada and more than 25% of the attendees are residents of Canada. ... Taxable supply Permanent establishment Supply Zero-rated supplies Associated person Small supplier Goodwill Capital property Exempt supplies Convention Page details Date modified: 2023-12-21 ...
Old website (cra-arc.gc.ca)
Guidance on enhanced financial accounts information reporting
Tax Convention 3.43 Plans or arrangements established in Canada described in paragraph 3 of Article XVIII (Pensions and Annuities) of the Convention between Canada and the United States with Respect to Taxes on Income and on Capital include superannuation, pension, or other retirement arrangements. ... "In trust for" accounts 6.52 Many financial institutions open accounts under an "in trust for" (ITF) convention but there is no consistent industry approach to ITF account naming conventions. ... The financial institution opens the account using the ITF naming convention. ...
Administrative Policy summary
RC4082 "GST/HST Information for Charities" 6 December 2021 p. 14 -- summary under Subsection 225.1(2)
Step 2- Determine the total of: all ITCs you are claiming for purchases of, or improvements to, real property and capital property for use more than 50% in commercial activities, including the deemed tax payable when capital property is brought into a participating province to use in your commercial activities; any ITC on your acquisition of, or improvement to, real property based on its percentage of use in your commercial activity (must be more than 10%) and for which you filed Form GST26, Election or Revocation of an Election by a Public Service Body to Have an Exempt Supply of Real Property Treated as a Taxable Supply, that is effective the day you acquired the property; any ITC equal to the basic tax content of real property just before an election (Form GST26) filed by you takes effect to treat that property as a taxable supply and any ITC on the deemed purchase of that property based on its percentage of use in your commercial activity (must be more than 10%), where the election takes effect on a day other than the day you acquired the property or became a registrant; all ITCs for goods you bought, imported or brought into a participating province that are sold by an agent or an auctioneer acting as your agent; all ITCs for goods you imported on behalf of a non-resident for use exclusively in your commercial activities and sold when you are acting as an agent, or auctioneer and agent for the non-resident person; 60% of the total of the GST/HST adjustments (for example, for price reductions and rebates for foreign conventions, for short-term accommodation in tour packages, and for artistic works produced for export) or of point-of-sale rebates for the provincial part of the HST that the charity gave in the reporting period (no amount should be included for any Ontario First Nations point-of-sale relief credited in the reporting period a the charity may claim this amount by filing Form GST189, General Application for Rebate of the GST/HST, using code 23). all amounts for GST/HST adjustments you gave for tax charged in excess of the GST/HST collectible on certain supplies of property and services; all GST/HST adjustments you gave for tax collected in error or bad debts you wrote off during the period for the sale of real property or capital property; all GST/HST adjustments for new housing rebates you credited during the period; and all ITCs that you were entitled to claim and that you carried forward from a reporting period when you did not have to use this net tax calculation for charities. ...
Miscellaneous severed letter
11 August 1998 Income Tax Severed Letter E9819311.txt - TAX ON SIGNING BONUS - NON-RESIDENT ATHLETE
As the words “salary or wages” are not defined in Canada’s Conventions, these words have the same meaning for the purposes of the Dependent Personal Services Article of the Conventions as they do under the Act by virtue of the General Definitions Article in the Conventions or section 3 of the Income Tax Conventions Interpretation Act (the “ITCIA”). ... Income Tax Convention (the “U.S. Convention”) The Dependent Personal Services Article of the U.S. ... Convention which applied to income not otherwise dealt with in that Convention. ...
Miscellaneous severed letter
11 August 1998 Income Tax Severed Letter 9819311 - TAX ON SIGNING BONUS - NON-RESIDENT ATHLETE
As the words “salary or wages” are not defined in Canada’s Conventions, these words have the same meaning for the purposes of the Dependent Personal Services Article of the Conventions as they do under the Act by virtue of the General Definitions Article in the Conventions or section 3 of the Income Tax Conventions Interpretation Act (the “ITCIA”). ... Income Tax Convention (the “U.S. Convention”) The Dependent Personal Services Article of the U.S. ... Convention which applied to income not otherwise dealt with in that Convention. ...
FCA
John Hale v. Her Majesty the Queen, [1992] 2 CTC 379, 92 DTC 6370
The Convention does not define the words "salaries, wages and other similar remuneration”. ... This fact is indicated in the preamble to the Convention. Accordingly, it is undesirable to look beyond the four corners of the Convention and Protocol when seeking to ascertain the exact meaning of a particular phrase or word therein. ... Notwithstanding the provisions of a convention or the Act giving the convention the force of law in Canada, it is hereby declared that the law of Canada is that, to the extent that a term in the convention is (a) not defined in the convention, (b) not fully defined in the convention, or (c) to be defined by reference to the laws of Canada, that term has, except to the extent that the context otherwise requires, the meaning it has for the purposes of the Income Tax Act, as amended from time to time, and not the meaning that it had for the purposes of the Income Tax Act on the date the convention was entered into or given the force of law in Canada if, after that date, its meaning for the purposes of the Income Tax Act has changed. 4 Article 7(1) of the Convention reads as follows: Article 7 Business profits 1. ...
FCTD
Montreal Aluminium Processing Inc. And Albert Klein v. Attorney General of Canada and Minister of National Revenue, [1991] 2 CTC 70, 91 DTC 5424
Tax Convention Act, 1984 (the “Tax Convention Act’, S.C. 1984, c. 20), when read with the Convention, for the legal compulsion of information or production of documents sought by the U.S. ... As indicated above, the Convention was incorporated into Canada's domestic law by virtue of the Tax Convention Act. ... Section 3 of the Tax Convention Act clearly states that the Convention has the force of law in Canada. ...