Search - convention

However, it should be noted that the applicable Income Tax Convention may provide for different results. ...

Income Tax Convention (1978) provides no such relief. In the event the above information does not satisfy your requirements, we would be prepared to review a more specific enquiry detailing the residency status of the employee, complete information concerning the plan involved, etc. ...

Campbell Specialty Rulings Division   File No. 90M03335 Permanent Establishments- Offshore Rigs You wrote to us concerning the application of the Canada-United States Income Tax Convention and the determination of permanent establishments using the concept that space was available in certain circumstances. ...

Income Tax Convention. The transactions described in your letter appear to reflect a factual situation and in our view should be handled as an advance income tax ruling request. ...

Hartwick of your division dated March 17, 1990 where we describe our rationale for concluding that a taxpayer described in subsection 149(1) is a "taxpayer subject to tax under Part I of the Act" as required under paragraph 115(2)(c.1) of the Act.  24(1)  24(1)  We should, however point out that the terms of any resident would have to be reviewed to determine whether the convention would override the provisions of the Act. ...

Where the Governor-in-Council, by order, has allowed an international organization to have the privileges and immunities set forth in Article II of the Convention on the Privileges andImmunities of the United Nations, section 7 thereof exempts its assets, income and other property from all direct taxes in Canada.  ...

We are also of the opinion that an amount received by a Canadian resident as a distribution from a U.S. qualified pension plan and rolled over into an IRA is pension income that would be excluded from taxable income in Canada within the meaning of paragraph 1 of Article XVIII of the Income Tax Convention. ...

The Canada-United Kingdom Tax Convention provides that there is no withholding of tax in the U.K. on the first $10,000 (5,000) of pension income. ...

De plus, le contribuable est autorisé, dans le calcul de son revenu imposable, à déduire, en vertu du sous-alinéa 110(1)f)(i) de la Loi et du paragraphe 5 de l'article XVIII de la Convention fiscale de 1980 entre le Canada et les États-Unis, la moitié du montant de prestations de sécurité sociale des États-Unis inclus dans son revenu. ...

Income Tax Convention, such payments made to the U.S. resident will be subject to a 10% withholding tax. ...