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Instead, the lending fee would either be subject to tax pursuant to subparagraph 212(1)(d)(i) of the Act for the use of property in Canada or will be considered business profits in accordance with the provisions of Article V and VII of the Canada-United States Tax Convention (1980). ...

Tax Convention 1980 to the type of transactions described above. This memo also points out that, generally, for Canadian resident shareholders who are not citizens of the U.S. there is no potential for double taxation and that there may be relief from double taxation of Canadian resident shareholders who are U.S. citizens if they apply to the U.S. tax authorities for such relief. ...

HBW4125I7 F- Withholding Tax Requirements on Loans Unedited CRA Tags n/a 19(1) HBW 4125-I7   Jim Wilson   (613) 957-2063 January 10, 1990 Dear 19(1) We are writing in regards to your letter of November 27, 1989, concerning the Canadian withholding tax requirements on loans subsidized by 24(1) Under Article XI of the Canada-Italy Income Tax Convention, Canada would withhold 15% on all interest payments made to the 24(1) Paragraph 3(c) of Article XI provides that if the loan is guaranteed or insured by an institution specified and agreed upon by letters exchanged between the competent authorities, the interest would not be taxable in Canada.  ...

By virtue of subparagraph 2(a) of Article XVIII of the Canada-United States Income Tax Convention, 1980, the tax that Canada may impose on the payments here in question will be limited to an amount not in excess of 15 percent of the gross amount of such payments provided the plan qualifies as a pension as defined in paragraph 3 of that Article. ...

Ce même paragraphe mentionne également que l'article 7 de la Loi s'applique lorsqu'une corporation consent à vendre des actions d'une corporation avec laquelle elle a un lien de dêpendance, à un prix inférieur à leur juste valeur marchande ou sans contrepartie monêtaire. 24(1) Ce régime semble plutôt viser par les dispositions du paragraphe 8 du Bulletin d'interprétation IT-113R3, c'est-à-dire être une convention où l'employeur choisit de verser des espèces, lesquelles dans le présent cas, sont remises au fiduciaire.  ...

Response: With respect to taxation issues, the provisions of the Canada-Netherlands Income Tax Convention would apply and in this regard we have attached a copy of Article XII, which deals with remuneration for services. ...

Accordingly, you are of the view that interest payments from Canco to the Swedish parent would not be subject to Part XIII withholding taxes because of paragraph 6 of Article 11 of the Canada-Sweden Income Tax Convention. ...

The Canada-United States Income Tax Convention (1980) does not provide for a reduction of Part XIII tax on such rental income.       ...

Income Tax Convention permits Canada to tax such royalty payments made to U.S. residents, however, the rate of withholding tax on such payments is limited to 10% of the gross amount of the royalty payments. 21(1)(b) for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch ...

Income Tax Convention reduces the withholding rate to 10 per cent where the use payments are made to a resident of the United States. ...