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In general we are of the opinion that exempt organizations are “residents of a contracting state” for purposes of a particular tax treaty if that treaty contains a residence definition similar to that contained in the Canada-United States Income Tax Convention (1980). ...

Section 3(1) of the Order refers to Article V of the Convention with the United Nations. ...

Article XII(3) of the Canada-United States Income Tax Convention further supports this withholding exemption. ...

The Canada-Austria Income Tax Convention Act, 1989 provides, however, that where the interest would be subject to tax in Austria the withholding rate is 15%. ...

However, the object and purpose of the Convention would in their view be over ridden and a double exemption given to the income. ...

Where the facts of a particular situation are such that Article VII of the new Convention has application to management fees paid by a Canadian subsidiary to its U.S. parent, it is the Department's position that there is no obligation on the payor to withhold tax under subsection 215(1) of the Act. ...

Income Tax Convention. Problem: A sporting event is transmitted live (without any delay) to a Canadian broadcaster who immediately broadcasts the signal to Canadian viewers. ...

Tax convention, by virtue of the provisions of paragraphs 212(13.1)(b) and 214(3)(a) and subsection 212(2) of the Income Tax Act. ...

10 May 1990 Income Tax Severed Letter RRRR381- Whether a particular lump-sum payment from the Netherlands is from a pension Unedited CRA Tags 6(1)(g), 60(j), 248(1), Canada-Netherlands Income Tax Convention Article 18 DATE May 10, 1990 TO FROM A Enquiries and Taxpayer DE Financial Industries Division Assistance Division D.S. ...

Income Tax Convention (1980). Accordingly, the 25% Part XIII withholding tax under paragraph 212(1)(q) of the Act will be reduced to 15% by reason of part 2(a) of that Article where such amounts are paid to a U.S. resident. ...