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Tax Convention (the "U.S. Convention") and the resident of the second country is entitled to benefits under Canada's treaty with the second country. ... The LLC is owned one-third each by a U.S. resident, a resident of another country with which Canada has an income tax convention, and a resident of a third country with which Canada does not have an income tax convention. ... Tax Convention, we would not be opposed if you took the view, administratively, that the purchaser may file a T2062C Notice in respect of the LLC. ...

Furthermore, section 18 of Article V of the Convention on the Privileges and Immunities of the United Nations ("Convention") provides exemption from tax to those United Nations officials on the salaries and emoluments paid to them by the United Nations. ... As the ICJ is the principal judicial organ of the United Nations, the Department would recognize any tax exemptions granted to it or its employees and officials pursuant to the Convention on the Privileges and Immunities of the United Nations ("Convention"). ... As pension income from the ICJ is taxable under the Act, the Department must then consider the application of an income tax convention to ensure that Canada's right to tax has not been restricted or denied by the application of that particular convention. ...

De plus, selon les dispositions du paragraphe 207.6(2) de la Loi, l’employeur est réputé être le dépositaire d’une convention de retraite. Le droit dans la police d’assurance-vie est réputé être un bien déterminé de la convention de retraite. Un montant égal au double de toute prime versée sur la police est réputé être une cotisation versée dans le cadre de la convention. ...

Income Tax Convention (the "Convention"), Canada has the right to tax this income and the U.S., not Canada, should be granting credit in respect of the Canadian tax. Paragraph 2 of Article XXIX of the Convention states that, except as provided in paragraph 3, nothing in the Convention shall be construed as preventing Canada from taxing its residents and, in the case of the U.S., its citizens, as if the Convention did not exist. ... If the Convention is read without regard to paragraph 2 of Article XXIX, "Canadian source" income received by a resident of Canada would not be subject to tax in the U.S. under the Convention and such income would therefore be deemed to arise in Canada for purposes of Article XXIV. ...

Where the conditions in paragraph 81(1)(c) of the Act are not met, one would then go to the Convention to find out if there is any relief provided by the Convention. ... The term "international traffic" is not defined in the Convention. However, XXXXXXXXXX of the Convention states: "XXXXXXXXXX". ...

Income Tax Convention (the "Convention") This is in reply to your letter of October 19, 1992 wherein you requested our opinion on a number of questions concerning the following hypothetical situation. ... On the assumption that the partnership is not carrying on business in Canada through a permanent establishment and the sale of shares of Canco does not fall within paragraph 1 of Article XIII of the Convention, the pro rata share of the gain realized by the partnership from the disposition of its shares in Canco which flows through to Y will fall within paragraph 4 of Article XIII of the Convention and will not be taxable in Canada. 2. Reasonable management fees which are paid to a resident of a country with which Canada has a tax convention or agreement will generally fall within the business profits article. ...

Convention (1942) as "royalties for the right to use copyright". ... Income Tax Convention (1942) applied to exempt such payments from withholding tax. ... Income Tax Convention (1942) (see The Queen vs. Saint John Shipbuilding and Dry Dock Co. ...

Tax Convention, 110(1)(f), 56(8), 120.3 Principal Issues: What is the correct treatment of a U.S. ... " You also noted that the guidance provided in IT-122R2 appears to contradict paragraph 5 of Article XVIII "Pensions and Annuities" of the Canada- United States Tax Convention (the Convention). ... Article 2 of the Technical Explanations of the Fourth Protocol of the Convention provides an explanation of paragraph 5(a) of Article XVIII of the Convention. ...

Income Tax Convention (1980) (the "Convention") in accordance with Article IV of the Convention ("U.S. ... Pension Fund, Master Trust or Charitable Organization which is constituted in the United States will pursuant to subparagraph (1)(b) of Article IV of the Convention, be considered to be a resident of the United States for the purposes of the Convention. ... E.Provided that a U.S. investor that acquires units of the Fund or a U.S.investor who is a member of a partnership that acquires units of the Fund, did not become a resident of the United States for the purpose of obtaining the benefits of the Convention and can reasonably be considered the beneficial owner of the income distributed by the Fund, the benefits of the Convention will not be denied to the investor as contemplated by paragraph 7 of Article XXIXA of the Convention. ...