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Paragraph 6 of Article XXI of the Canada-United States Income Tax Convention, a copy of which is attached for your perusal, outlines the rules applicable to gifts made by a resident of Canada to an organization which is resident in the United States. ...

Income Tax Convention 1980, where there is dual residency, deems a corporation to be resident in the country in which it was incorporated for purposes of the treaty. ...

Tax Convention in the following hypothetical situation. 1. Mr. A is a non-resident of Canada and is a resident of the U.K. for U.K. tax purposes but is not domiciled or ordinarily resident in the U.K. ...

Income Tax Convention (1978) We have a case on hand in which the branch operation of a Canadian bank in London is subjected to different taxation than U.K. banks. 1. ...

Weil Section 4 RE: Proposed Canada-United Kingdom Income Tax Convention Your memo of December 14, 1978, J.E. ...

Income Tax Convention (1980) Article XXI At the suggestion of Mr. J. M. ...

Kuss (613) 957-2120 November 12, 1986 Dear Sirs: Re: Canada-Brazil Income Tax Convention (the "Treaty") We would like to clarify our position stated in our letter dated February 27, 1986 which was in response to your letter of December 19, 1986. ...

INCOME TAX CONVENTION On October 15, 1981 you were good enough to advise us of the Department's assessing position with respect to dividends received from U.K. corporations in light of Article XXVII(4) of the above treaty. ...

Article XXI(5) of the new Canada-United States Income Tax Convention sets out the conditions under which such deductions may be allowed for purposes of United States taxation. ...

If on filing the return for the year, it is concluded that under the Act or the Convention the tax withheld is in excess of that required, the surplus will then be refunded. ...