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Furthermore, the Income Tax Conventions Interpretation Act provides a deeming provision that provides that, for purposes of our tax treaties, a payment received out of an RRSP is a payment out of a pension. ... An RRSP may be treated by Canada as a pension plan for purposes of the Canada-Netherlands Income Tax Convention, by virtue of the Canadian Income Tax Conventions Interpretation Act. ...

Tax Convention. In addition, you are of the opinion that the following characteristics of interest as set out in the Interest Act have been met: a) the amount must be compensation for the use of a sum (principal) of money; b) the amount must be referable to the sum (principal); c) the amount must be calculated by reference to the time the sum (principal) is outstanding. ... Tax Convention. However, only once a particular non-resident's tax liability has been established under the Act can we look to the terms of a particular tax treaty, if one exists, to determine what, if any, relief from such taxation may be available. ... Tax Convention. As we understand, the financing subsidy payments were made by ACO to BCO in order to induce BCO to extend credit on favorable terms to the U.S. distributors of ACO and are calculated by reference to interest foregone by BCO. ...

Income Tax Convention (1980).  The deduction does not apply to an amount described in 2(a) above because the amount that would normally be deductible (i.e., the individual's own contributions) is already excluded from income under subparagraph 6(1)(g)(ii) of the Act. 4.      ... Income Tax Convention (1978).      (c)  Where the amount is paid to a U.S. resident in the form of a pension, the 25% withholding tax referred to in 8(a) above is reduced to 15% by virtue of part 2(a) of Article XVIII of the Canada-U.S. Income Tax Convention (1980). 9.     Whether or not the U.K. or U.S. tax authorities would allow a tax credit in respect of Canadian withholding tax is a matter to be resolved between the recipient and the U.K. or U.S. tax authorities. ...

A titre d'exemple, c'est ce que l'on a décidé en matière de convention matrimoniale dans les trois causes mentionnées ci-dessous: SURA c. ... (p.1012) (nos soulignés) Puis, la Cour suprême a réitéré sa position dans l'affaire Simon:      "Quelle que soit la nature de la communauté, à sa dissolution par la mort du mari donnant naissance à l'application de la stipulation précitée des conventions matrimoniales, la veuve est devenue propriétaire de tous les biens rétroactivement à la date du mariage". ... Ce raisonnement, appliqué à la totalité des biens lorsque les conventions matrimoniales contiennent une stipulation complète en faveur du survivant, amène nécessairement à la conclusion qu'il n'y a pas ici "transmission" donnant ouverture à cotisation... ...

Income Tax Convention ^SC1984c20 Art. 4 923188 19(1) Jim Wilson (613)957-2123 November 12, 1992 Dear 19(1) We are writing in reply to your letter dated October 19, 1992, concerning your tax status in Canada. 19(1) The following general comments may be of some assistance: 1. ... In both cases (i.e. residents and non-residents of Canada), Canadian tax implications are subject to all relevant income tax conventions. 5. As you are aware, there is a Convention between Canada and the U.K. for the avoidance of double taxation and the prevention of fiscal evasion (the "treaty"). ...

A titre d'exemple, c'est ce que l'on a décidé en matière de convention matrimoniale dans les trois causes mentionnées ci-dessous: SURA c. ... (p.1012) (nos soulignés) Puis, la Cour suprême a réitéré sa position dans l'affaire SIMON: "Quelle que soit la nature de la communauté, à sa dissolution par la mort du mari donnant naissance à l'application de la stipulation précitée des conventions matrimoniales, la veuve est devenue propriétaire de tous les biens rétroactivement à la date du mariage". ... Ce raisonnement, appliqué à la totalité des biens lorsque les conventions matrimoniales contiennent une stipulation complète en faveur du survivant, amène nécessairement à la conclusion qu'il n'y a pas ici TRANSMISSION donnant ouverture à cotisation... ...

Income Tax Convention (the "treaty") (see our comments below re "international traffic"), such profits would be taxable in Canada by virtue of Article VII of the treaty only to the extent that they are attributable to a permanent establishment in Canada through which the U.S. airline carries on business in Canada. ... For the purposes of this Convention, the term 'permanent establishment' means a fixed place of business through which the business of a resident of a Contracting State is wholly or partly carried on. ... For the purposes of the Convention, the provisions of this Article shall be applied in determining whether any person has a permanent establishment in any State. ...

Income Tax Convention Principal Issues: Canadian tax issues for U.S. resident employers of Canadian resident employees under remote work arrangements. ... Income Tax Convention (the “Treaty”) and is entitled to benefits under the Treaty (i.e., USco is a “qualifying person” for purposes of Article XXIX-A of the Treaty). ... Consistent with the Commentary on the OECD Model Income Tax Convention, a home office of an employee, in and of itself, does not create a permanent establishment for USco. ...

Graham Assessment, Benefit and Service Branch 2022-092973 Application of the Canada-Italy Tax Treaty to CPP and OAS benefit payments This is in reply to your e-mail enquiry of March 8, 2022 regarding the application of the Convention Between The Government Of Canada And The Government Of The Italian Republic For the Avoidance of Double Taxation With Respect to Taxes on Income and the Prevention of Fiscal Evasion (“Treaty”) to Canada Pension Plan (“CPP”) and Old Age Security (“OAS”) benefit payments made to an individual that is resident in Italy. ... In such a case, section 5 of the Income Tax Conventions Interpretations Act provides a definition of the term “pension” in respect of payments that arise in Canada. ... Notwithstanding any provision of this Convention: … (b) benefits under the social security legislation in a Contracting State paid in a calendar year to an individual who is a resident of the other Contracting State shall be taxable only in the State in which they arise and according to the laws of that State but the tax so charged shall not exceed the amount that the recipient would otherwise be required to pay in that year if the recipient were a resident of that first-mentioned State…” The Protocol of Understanding (“Protocol”) to the Treaty contains additional provisions, including paragraph (j) which states, in part, the following: “(j) For the purposes of subparagraph (b) of paragraph 3 of Article 18, the term “social security” means: (a) in the case of Canada, any pension or benefit paid under the Old Age Security Act of Canada” While both CPP and OAS payments may generally be considered to be social security benefits, only the OAS payments are considered to be social security benefits under the Treaty in accordance with paragraph (j) of the Protocol. ...

CANADA/US INCOME TAX CONVENTION RULINGS T. KUSS 6. DISCOUNTS REALIZED BY INVESTORS RULINGS M. ... Income Tax Convention (the "Convention") states that the Convention applies to the taxes imposed by the Government of Canada (Parts I, XIII and XIV of the Income Tax Act (the "Act")) and, in the case of the U.S., taxes imposed by the Internal Revenue Code (the "Code"). ... 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. ...