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6 May 1986 Income Tax Severed Letter 95-1045 F Dear XXX This is in reply to your letter of February 13, 1986 in which you request our opinion on whether Article II of the Canada-Norway Income Tax Convention (the "treaty") exempts residents of Norway from Canadian tax in respect of rental income from moveable property. ...

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. ...

Income Tax Convention (1942). We agree that the provisions of Article XIIIC exempt from tax, otherwise imposed by subsection 212(5) of the Income Tax Act, payments made for the right in or to the use of a videotape for use in connection with television broadcasting. ...

Income Tax Convention, notwithstanding our previous opinion to the contrary given to you on October 14, 1981. ...

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. ...

We note that there is nothing in the Canada-Netherlands Tax Convention which overrides the Act in this regard. ...

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%. ...

17 June 1987 Income Tax Severed Letter 97063-4 F Issue: Whether payments to a U.S. resident for a live telecast of a sporting event are subject to Part XIII tax and, if so, is the rate of withholding tax reduced or eliminated pursuant to either Canada-U.S. income Tax Convention. ...

10 April 1990 Income Tax Severed Letter HBW941223B F- Sovereign Immunity Unedited CRA Tags n/a 19(1) Jim Wilson   (613) 957-2063   HBW 9412-2-3 April 10, 1990 Dear 19(1) Re:  Sovereign Immunity 24(1) We are writing in reply to your letter dated February 21, 1990, concerning tax exemption for  24(1) Article XXI of the Canada-United States Income Tax Convention does not apply as the 24(1) is not a resident of either contracting state. 24(1) may be eligible for exemption from Canadian withholding tax under the Doctrine of Sovereign Immunity.  ...

Although we will not rule on how the proposed transaction described in your ruling request would be viewed for purposes of the Income Tax Act (the "Act"), should your client decide to proceed with the proposed transaction you may wish to consider the impact, if any, of subsection 212(13) of the Act and Article XII of the Canada-Singapore Income Tax Convention, 1976. ...