Search - convention

3 January 2001 Internal T.I. 2000-0024247- Section 6.2 of Income Tax Convention-- summary under Section 6.2 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 6.2 Article 20 of the Canada-New Zealand Convention provides that items of income of a resident of New Zealand which are not dealt with in other Articles and which are derived by the resident from sources in Canada may be taxed in Canada according to the laws of Canada. A gain of a resident of New Zealand from a disposition of shares of a private Canadian corporation that were taxable Canadian property was subject to Canadian capital gains tax given that it had been the intention of the Canadian negotiators of Canadian ncome tax conventions that the source of income on a disposition of taxable Canadian property is from Canada and this intention was confirmed, for greater certainty, by s. 6.3 of the Income Tax Convention Act. ...

3 January 2001 Internal T.I. 2000-0024247- Section 6.2 of Income Tax Convention-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Article 20 of the Canada-New Zealand Convention provides that items of income of a resident of New Zealand which are not dealt with in other Articles and which are derived by the resident from sources in Canada, such income may be taxed in Canada according to the laws of Canada. A gain of a resident of New Zealand from a disposition of shares of a private Canadian corporation that were taxable Canadian property was subject to Canadian capital gains tax given that it had been the intention of the Canadian negotiators of Canadian Income Tax Convention that the source of income on the disposition of taxable Canadian property is from Canada and this intention was confirmed, for greater certainty, by s. 6.3 of the Income Tax Convention Act. ...

Convention (U5-100-18)")-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 If a payment out of a RRIF qualifies as a "periodic pension payment" as defined under the Income Tax Conventions Interpretation Act, and it is paid to a resident of the U.S., the Canadian non-resident withholding tax on such payment will be 15% of the gross amount of the RRIF payment pursuant to paragraph 2(a) of Article 18 of the U.S. Convention. ...

Convention-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 "rental property" means property rented by the company as landlord/lessor With respect to the exclusion in paragraph 7 of Article XIII of the Canada-U.K. Convention for property (other than real property) in which the business of the company is carried on, RC is of the view that: rental property means property rented by the company as landlord/lessor; office buildings, factories, processing plants and fixed machinery and equipment operated by the company together with the land under or subjacent thereto and necessary for use thereof qualify; and oil and gas reserves, mines and well interests qualify if the owner is actively engaged in the exploitation of natural resources subject to the exception relating to hydrocarbons contained in the Convention; and that immovable property that is inventory or property not used in the business but held as an investment for capital gains, will not qualify. ...