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2 April 1992 External T.I. 9203006 F - Determination of Where Business Principally Carried On

Aylward 920300 Subject: Article X of the Canada-Switzerland Income Tax Convention (1976) (the "Convention") This is in response to your memorandum dated January 29, 1992 concerning the interpretation of paragraph 6 of the above Article. ... Paragraph 6 of the Convention provides that the term "earnings" for the purposes of determining branch tax: "... does not include profits attributable to a permanent establishment in Canada of a company which is a resident of Switzerland earned in a year during which the business of the company was not carried on principally in Canada. ... In our view these other criteria would also be relevant in determining whether or not the business of a company is carried on principally in Canada for the purposes of paragraph 6 of Article X of the Convention. ...

12 July 2002 External T.I. 2002-0151035 - Article 21 of Poland Treaty

Stalker July 12, 2002 Dear XXXXXXXXXX: Re: Article 21 of the Canada-Poland Tax Convention (the "Convention") This is in reply to your facsimile to us dated July 6, 2002, requesting our views regarding the above-noted subject matter. ... We confirm that in determining whether or not the estate or trust income is taxable in Poland, the impact of paragraph 2 of article 23 of the Convention is not considered. ...

18 March 1992 External T.I. 9203235 F - Rental Payments on Moveable PPTY Used in Canada

Harding 957-2111 Attention: 19(1) March 18, 1992 Dear Sirs: Re: Canada-Norway Income Tax Convention (the "Convention") This is in reply to your letter of January 30, 1992 wherein you requested clarification of our position concerning the receipt of rents by a lessor who is a resident of Norway for the use of moveable property in Canada. ... Generally rental payments for movable property used in Canada and received by a corporation resident in Norway, by virtue of Article 6 of the Convention, will be exempt from tax in Canada unless the corporation carries on business in Canada through a permanent establishment. ...

Ntakirutimana v. Canada (Citizenship and Immigration), 2016 FC 272

The decision rejected their application for permanent residence as members of the class of Convention refugees abroad or the class of humanitarianprotected persons abroad. ... Furthermore, South Africa is a signatory country of the Refugee Convention, and the principle of nonrefoulement is written into in its legislation. [15] There is no further evidence in the file to enlighten the Court as to the certification process for refugee status in South Africa, whether there is one, or whether the applicants used it. ... The Convention and the Immigration Act should be interpreted with the correct purpose in mind.” ...

William C Krafve v. Minister of National Revenue, [1984] CTC 2021, 84 DTC 1002

When the Canada-US Tax Convention was signed, the Canadian Income Tax Act did not read the same then as it was changed in 1971. ... The words “disposition” or “alienation” were not used in Article VIII of that Convention. ... I simply say that the Convention between Canada and the United States is not relevant for the reasons expressed above. ...

Her Majesty the Queen v. Russell a Hunt, [1977] CTC 578, 77 DTC 5404

By statute, the Convention has the force of law. Article VIII A provides: Article VIII A. ... The plaintiff then asserted reliance on sections 2, 3 and 5 of the Income Tax Act, RSC 1952, c 148, and Article VIIT A of the Convention. ... At the trial, however, counsel for the defendant in his Opening statement took the position that the defendant fell within Article VIII A of the Convention and was in fact exempt from January 1 to June 30, 1970, and he offered evidence to establish the defendant’s right to the exemption. ...

Maritime Coastal Containers Limited v. Minister of National Revenue, [1981] CTC 2227

There is nothing in article 21, or in any other article of the said Convention, requiring Canada to forego its tax in respect of interest payable pursuant to its own Income Tax Act. Article 10 of the Canada-Norway Income Tax Convention permits taxation of interest arising in one contracting state (Canada) and paid to the resident of another contracting state. The definition of “interest” in article 10(6) of the said Convention is wide enough to include the payments made in the present case. ...

11 February 1986 Income Tax Severed Letter 7-0084 - []

Income Tax Convention, 1980 We have been asked to review the Commentary to the Canada- U. ... Under Article XVIII(3) of the Convention, however, the term pensions includes a pension or retirement plan. ... Another rule of interpretation relevant to question 1) is found in Article 111(2) of the Convention. ...

11 September 2007 External T.I. 2006-0195851E5 F - Crédit pour impôt étranger

La convention fiscale Canada-Roumanie (ci-après la "Convention") ne prévoit aucun allégement d'impôt à l'égard des frais de gestion, ni ne traite spécifiquement de ce type de revenu. 6. L'article 21 de la Convention stipule ce qui suit: Autres revenus 1. ... Peut-on considérer que les frais de gestion sont visés par l'article 21 de la Convention? ...

29 November 2006 External T.I. 2005-0140621E5 - Income allocated to retired partner

Income Tax Convention? Position: No Reasons: In our view, the payments are business profits under the Convention. ... Income Tax Convention (the "Convention") limits the rate of Canadian tax on these payments to 15%. ... Therefore, the 15% limit under Article XVIII(2) of the Convention does not apply to the Taxpayer. ...

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