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Income Tax Convention (1978) (if applicable) or other rate of withholding tax normally applied on payments to non-residents.  ...

Toutefois, si le droit de vote est uniquement rattaché aux actions en vertu d'une loi sur les compagnies et non un droit de vote qui fait partie intégrante des caractéristiques des actions ou d'une convention y relative, nous sommes d'avis qu'un tel droit de vote ne devrait pas empêcher ces actions d'être des actions d'un catégorie exclue, pourvu que les autres conditions du paragraphe 256(1.1) de la Loi soient rencontrées. ...

The rate of Spanish tax payable by the bank in respect of the interest is limited to 15%, pursuant to Article II of the Canada-Spain Income Tax Convention (the "Treaty"). ...

The Finnish National Old Age Pension does not meet the definition of "pension" or "annuity" under Article II of the Canada-Finland Income Tax Convention (1958). ...

It is your view that, notwithstanding that the individual is deemed to be a resident of the United States and not of Canada pursuant to Article IV of the Canada-United States Income Tax Convention, 1980 (the "treaty"), the individual will meet the residence requirement of subsection 110.6(3) of the Act and will not, by reason only of his residence status under the treaty, be denied the benefit of subsection 110.6(3) of the Act in that taxation year. ...

Tax Convention Canada-U.S. Tax Treaty:Art. VI, XII, XXX Q1. What is the tax rate for resource royalties under the new treaty? ...

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. ...

Income Tax Convention (1980). With respect to your reference to subsection 212(11) of the Act, it has been our longstanding position that where the payment is out of a trust governed by a pension plan, the particular provisions of paragraph 212(1)(h) of the Act override the general provisions of subsection 212(11) of the Act. ...

Income Tax Convention (1980). However, there is a provision of the Income Tax Act which allows you to elect to file a tax return as though you were a resident of Canada. ...

Income Tax Convention (1980) would exempt such payment from tax in Canada, except to the extent that the management fee was attributable to a permanent establishment in Canada of-A. ...