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XXXXXXXXXX 2000-004254 Attention: XXXXXXXXXX January 9, 2001 Dear Sir\Madam: Re: Canada-United Kingdom Income Tax Convention ("Treaty")- Article 13 This is in response to your facsimile letter dated August 16, 2000, wherein you requested our opinion on the application of the above noted provision of the Treaty in the following situation. ...

Income Tax Convention (the "treaty") Facts: On November 20, 1991 Doreen Guy (Ottawa D.O.) requested a technical interpretation regarding the above treaty articles. ...

XXXXXXXXXX Angelina Argento 2011-040355 July 15, 2011 Dear XXXXXXXXXX, Re: Article XV of the Canada-US Income Tax Convention (the "Treaty") This is in response to your email sent on April 18, 2011 wherein you asked us to assume the following facts: US Co is a corporation that is resident of the United States ("US") for the purposes of the Treaty. ... The Technical Explanation to the Treaty states that subparagraph 2(b) of Article XV is intended to have the same meaning as the analogous provisions in the U.S. and OECD Model Income Tax Convention ("Model Treaty"). ...

., a limited liability company incorporated in Norway. f) "Canada" means Canada as defined in section 5 of the Income Tax Conventions Interpretation Act, R.S.C. 1985, c. ... The charter may cover varying periods of time and a daily or monthly fixed rate is paid for the charter. y) "Tax Treaty" means the Canada-Norway Income Tax Convention. ...

Income Tax Convention to Structures with Multiple Tiers of Fiscally Transparent Entities A U.S. resident corporation that has elected to be classified as a “real estate investment trust” (“REIT”) under the applicable provisions of the U.S. ... Income Tax Convention (the “Treaty”). US LLC 1 makes an interest bearing loan to US LLC 2. ...

Income Tax Convention: Exempt Pensions/ 33. Regulations to Section 482 of the Internal Revenue Code- Transfer Pricing/ 34. ... The Protocol to the Income Tax Convention between Canada and the Netherlands contains such an exemption. ... Income Tax Convention (the Convention). (a)Would an U.S. Individual Retirement Account (IRA) be treated as a pension in the same manner as RRSPs and RRIFs and be entitled to the exemption from Canadian withholding tax, with respect to interest and dividends, contained in paragraph 2(a) of Article XXI of the Convention? ...

Income Tax Convention). In such cases, would the individual be considered as having ceased to reside in Canada for purposes of subsection 128.1(4) of the Income Tax Act ("the Act")? ... The Department is of the view that such a corporation would not be a resident of Barbados for purposes of the tax convention because it is not liable for tax on its world income. ... As you may perhaps know, Canada did not have a tax convention with Hong Kong. 4. ...

For Japanese tax purposes, XXXXXXXXXX computed its income from carrying on business in Japan in accordance with the provisions of Article 7 of the Canada-Japan Income Tax Convention (the "Convention"). ... As a result, for FTC purposes more income was sourced to the Japanese permanent establishment than was reported in Japan as directed by the Convention. ... However, it used the CCRA's approach both in determining its profits for the purposes of the Convention and for accounting purposes. ...

Conference 2010 CTF Deemed PE Rule in Article V(9)(a) of the Canada-US Income Tax Convention Question 9 Under article V(9) of the Canada-US treaty, the existence of a permanent establishment (PE) may be triggered retroactively after the taxpayer's year-end, which can result in inadvertent non-compliance with respect to the filing of Canadian T1 personal income tax returns and the payment of taxes (or withholdings) on a timely basis. ...

Income Tax Convention ("Treaty") This is in reply to your letter dated September 30, 1996 in which you requested our opinion regarding a distribution out of a trust that is a resident of Canada (the "trust"). ...