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Tax Convention (the "U.K. Treaty"). XXXX may argue that it is exempt from tax by virtue of Article VII of the U. ...

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. ...

10 April 1990 Income Tax Severed Letter ACC9190- Sovereign Immunity 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. ...

All the partners of P are U.S. residents within the meaning of Article IV of the Canada-U.S. 1980 Tax Convention (the "Treaty"). ...

Income Tax Convention (1980), a trust resident in Canada with income beneficiaries in the U.S. may have dual residence. ...

Income Tax Convention. I have one follow up question which I would appreciate receiving your reply to in connection with your comments on page 2 of the said letter dealing with the source of the income where one U.S. resident concludes an agreement of sale in the United States with another non resident in respect of a "life insurance policy in Canada". ...

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

Senécal (613) 957-2074 HBW 4215-I7 November 2, 1989 Dear Ambassador: We would like to take this opportunity to send you further documentation dealing with the recent amendments to the Canada- Italy Tax Convention as they pertain to the tax treatment of pensions paid by the Italian Government to residents of Canada. ...

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

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. ...