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Muirhead: By this letter, we are requesting confirmation from you of our telephone conversation of late last week with respect to the interaction of the Income Tax Conventions Interpretation Act and the Canada-U.S. 1980 Tax Convention. Section 6 of the Income Tax Conventions Interpretation Act provides that the term "interest" does not include guarantee fees referred to in Paragraph 214(15) (a) of the Income Tax Act with respect to tax conventions entered into by Canada before November 19, 1974 if the guarantee fee was made pursuant to an agreement entered into before June 23, 1983. The greater relief provisions of the Canada-U.S. 1980 Tax Convention as contained in Paragraph 5 of Article XXX state that the 1942 convention applies for the first taxable year to which the provisions of the 1980 convention would otherwise have applied if such application of the 1942 convention would provide greater relief from tax. ...

Canada-Japan Income Tax Convention (1986) This Convention was signed on May 7, 1986 but has not yet been ratified. Once ratified, the above mentioned rate of 25% will be reduced to 10% (pursuant to Article II of the Convention) with respect to interest paid after the calendar year in which the Convention enters into force to a person who is considered to be a resident of Japan pursuant to Article 4 of the Convention. This Convention will enter into XXX ...

Canada-Japan Income Tax Convention (1986) This Convention was signed on May 7, 1986 but has not yet been ratified. Once ratified, the above mentioned rate of 25% will be reduced to 10% (pursuant to Article II of the Convention) with respect to interest paid after the calendar year in which the Convention enters into force to a person who is considered to be a resident of Japan pursuant to Article 4 of the Convention. This Convention will enter into XXX ...

This Convention (the 1980 Convention) provides separate rules for compensation received by entertainers and athletes in Article XVI. Under the previous Convention (the 1942 Convention) tax on compensation for personal services, including those provided by entertainers, was governed by the provisions of Article VII, a copy of which is also enclosed. ... Pursuant to paragraph 5 of Article XXX, however, if the provisions of the 1942 Convention were more favourable than those to which paragraph 2(b) applied, the 1942 Convention continued to apply for 1985. ...

Income Tax Convention (New)- Articles VI and XIII(9) September 4, 1985 C.G. Toussaint XXXX Dear XXXX This is in reply to your letter dated August 15, 1985, following our reply to your letters dated May 9 and August 8, 1985, concerning the application of Article XIII(9) of the Canada-United States Income Tax Convention (1980) (Convention) to resource properties. ... It is therefore our view that resource properties would not qualify for the benefits under Article XIII(9) of the Convention since they are not "capital assets" for the purposes of the Convention. ...

Reasons: Paragraph 1 to 3 of Article 6 of the Canada-United Kingdom Income Tax Convention would apply. ... Leung November 24, 2003 Dear XXXXXXXXXX: Re: The Canada-United Kingdom Income Tax Convention (the "Convention") We are writing in reply to your letter of July 3, 2003 in which you requested our view whether your interpretation of the provisions of the Convention is correct with respect to the facts of the following situation. ... Paragraphs 1 to 3 of Article 6 of the Convention read as follows: "1. ...

The Pakistani withholding tax is a tax covered by the Convention between Canada and the Islamic Republic of Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income ("Convention") in accordance with its Article II. ... Question You ask whether Article XXII of the Convention entitles Canco to claim a foreign tax credit for the amount of taxes withheld by Pakistanco. ... In this respect, the application of Articles VII and XII of the Convention to the given hypothetical situation has to be considered. ...

Cette convention a été incorporée à leur jugement de divorce du XXXXXXXXXX. ... Le XXXXXXXXXX, Monsieur et Madame ont signé une convention modificatrice des mesures accessoires. ... Par cette convention modificatrice, les parties conviennent de modifier la pension alimentaire. ...

Kuss Attention: XXXXXXXXXX March 10, 1995 Dear Sirs: Re: Article 21 of the Canada-Australia Income Tax Convention We are writing in reply to your letter dated March 7, 1995 requesting a technical interpretation regarding the application of Article 21 of the Canada-Australia Income Tax Convention (the "Convention") to the following hypothetical situation. Background A corporation which is resident in Australia under the Convention realizes a gain on the disposition of shares of a corporation resident in Canada. ... Absent any relief under the Convention the sale is taxable under the Act. ...

Tax Convention Principal Issues: Whether the Canada-US Tax Convention (“Convention”) provides relief from double taxation in circumstances where a Canadian resident is the sole member of a disregarded U.S. ... Since the SMLLC is not liable for U.S. income tax, the SMLLC is not a resident of the U.S. for purposes of applying the Canada-US Tax Convention (the “Convention”). ... As such, it is the CRA’s view that in the circumstances described there is no taxation not in accordance with the provisions of the Convention as contemplated by Article XXVI(1) of the Convention. ...