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Réponse de l’ARC D’entrée de jeu, il est important de rappeler que ce sont les termes de la convention de société de personnes qui prévoient les modalités afférentes au partage du revenu qu’elle réalise pour une année donnée entre ses associés, et non le paragraphe 96(1) L.I.R. ...

However, it is our view that those cases essentially deal with treaty interpretation issues in the application of the United Kingdom – United States Tax Convention and that their overall conclusions are not relevant for entity classification in Canada. ...

The CRA stated that the impetus for the change in administrative policy is its position that the US estate tax problems applicable to Canadian residents who held US personal use real property were generally resolved by the amendments to the Canada-United States Income Tax Convention. ...

6 March 2012 Ministerial Correspondence 2011-0431641M4- Canada-United States Tax Treaty Application Unedited CRA Tags Canada-United States Tax Convention Principal Issues: Non-resident withholding tax on income from U.S. sources. ...

Subsection 212(2) of the Act provides for a Part XIII tax of 25% on such a deemed dividend subject to any relief under the Canada-Korea Income Tax Convention. ...

Although LEEs are subject to Canadian taxes on employment income received from a Canadian Consulate, LEEs are exempt from federal tax in the US by virtue of Article XIX of the Convention. ...

Tax Convention that apply to exempt a receipt of WHCA annuities by Canadian residents from taxation by Canada. ...

The Canada-South Africa Income Tax Convention does not prevent Canada from taxing pension benefits received by a resident of Canada. ...

Income Tax Convention. We trust that our comments will be of assistence to you and we would be pleased to answer any further questions that you may have with respect to to this matter. ...

Income Tax Convention (1978), a pension payment, which includes a payment out of a superannuation or pension plan according to Article XVII(3), arising in the U.K. and paid to a Canadian resident is taxable in Canada pursuant to Article XVII(1)), b) the benefit is not part of a series of periodic payments, c) the benefit is attributable to services rendered by the recipient or his spouse in a period throughout which such person was not resident in Canada, and d) the amount is designated by the taxpayer in the taxpayer’s return of income under Part I of the Act for the year. ...