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Miscellaneous severed letter

19 March 1987 Income Tax Severed Letter 5-2751 F - [870319]

Parce que vous auriez choisi l'option de 4 ans offert en vertu de la convention collective avec votre employeur, vous recevriez un traitement réduit, équivalent à 87,5% de votre traitement habituel pendant les 4 années de l'option, incluant les six mois de congé. ...
Miscellaneous severed letter

29 August 1989 Income Tax Severed Letter AC58381 - Payments to U.S. Resident with respect to Software Purchases by a Resident of Canada

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

29 September 1982 Income Tax Severed Letter 7-2074 - [820929]

Income Tax Convention. Canadian residents could be deemed to have à gain. 21(1)(a) We understand that amendments to the Act to deny such gains and losses are currently being considered. ...
Miscellaneous severed letter

4 August 1987 Income Tax Severed Letter 3-1251 - [Advance Income Tax Ruling]

The rate of withholding tax applicable to the "dividend" would be subject to the Canada-U.S. tax convention in effect at the time the dividend is deemed to be paid. ...
Miscellaneous severed letter

6 November 1990 Income Tax Severed Letter

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 Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...
Miscellaneous severed letter

17 August 1987 Income Tax Severed Letter 7-1939 - [870817]

We further agree with XXXX that the above answer applies to non-resident crew members from both the Faroe Islands (not a treaty country) and Denmark (a treaty country), and that in the latter case the meaning of the term "Canada" contained in section 5 of the Income Tax Conventions Interpretation Act as well as the provisions of paragraph 3 of Article XIII of the Canada-Denmark treaty are irrelevant to this question. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...
Miscellaneous severed letter

8 August 1989 Income Tax Severed Letter AC58220 - Computer Software License Fees Earned from Canadian Sources

Income Tax Convention (1980). It is our understanding that in most cases this Canadian tax is creditable against U.S. income taxes. ...
Miscellaneous severed letter

12 April 1988 Income Tax Severed Letter 5-5376 - []

Income Tax Convention (1980)). We trust this is satisfactory for your purpose. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...
Miscellaneous severed letter

18 April 1990 Income Tax Severed Letter ACC9186 - Canadian Government Annuities

Paragraph 2(b), Article 18 of the Canada-United States Income Tax Convention reduces this withholding tax to 15%. ...
Miscellaneous severed letter

31 May 1985 Income Tax Severed Letter 5-7699 F - [850531]

En vertu d'une convention entre les actionnaires, un mandataire-dépositaire demande en 1985 à être nommé bénéficiaire de la police d'assurance-vie. ...

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