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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. ...

Income Tax Convention (1980) ("the Treaty"). The term "pensions" therein includes any payment "under a... retirement plan... ...

Tax Convention and U.K. income tax law. Also, as you are a resident of Canada you must include in your income for Canadian tax purposes your worldwide income which would include any income earned in the U.K. ...

Arsenault (613) 957-2126 19(1) Feb 25, 1991 Dear Sirs: Re: Article 13 of the Canada-United Kingdom Income Tax Convention (the "Treaty") This is in reply to your letter dated August 31, 1989 whereby you requested our opinion concerning the application of paragraph 7(b) of Article 13 of the Treaty to a mine and a mill. ...

" However, in our view, income tax treaties or conventions which exempt the profits derived from the operation of ships are concerned with the principal function, rather than with the form or incidental navigational capabilities of the particular structure. ...

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) 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. ...

Income Tax Convention (1978) does not provide relief to the taxpayer in these circumstances. ...

Income Tax Convention (the "U.S. Treaty"), payments made to a U.S. resident for the use in Canada of computer software are subject to a 25% Part XIII tax ("Canadian withholding tax") under the Canadian Income Tax Act. ...

Income Tax Convention, 1980 interest or dividends received by an RRSP from U.S. sources may be exempt from tax in the U.S. ...