Search - convention

In our view, these words clearly include a dividend in kind, as described above, and accordingly, such dividend would be subject to Part XIII tax at a rate of 25%, subject to any rate reduction afforded by the provisions of an applicable income tax convention. ...

Income Tax Convention. The foregoing comments represent our general views with respect to the subject matter of your letter. ...

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. ...

En outre, pour déterminer les conséquences fiscales découlant d’un régime, on doit vérifier si la définition donnée au paragraphe 248(1) des termes “entente d’échelonnement de traitement”, “convention de retraite”, “régime de prestations aux employés”, ou “fiducie d’employée” s’applique au régime. ...

(This employment income is neither reduced nor exempt from tax in Canada by virtue of an income tax convention between Canada and the employee’s home country and the employee has no other income from a Canadian source.) ...

Pursuant to Article 11 of the Canada- Netherlands Income Tax Convention (1986), interest arising in Canada and paid to a resident of the Netherlands is subject to withholding tax of 10 per cent of the gross amount of the interest. ...

Seidel Attention: XXXXXXXXXX July 27, 1994 Dear Sirs: This is in reply to your letter dated April 7, 1994 requesting our views with respect to the meaning of "permanent establishment" in Article V of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

If you are aware of an industry convention of valuing certain investments on a straight-line basis (which has been accepted by the Department) and you believe the strip coupon's resemblance to such investments supports a valuation on the same basis, you may wish to mention this to the Valuations Section identified above. ...

The Income Tax Conventions Interpretation Act defines Canada as follows; "Canada" means the territory of Canada, and includes (a)     every area beyond the territorial seas of Canada that, in accordance with international law and laws of Canada, is an area in respect of which Canada may exercise rights with respect to the sea bed and subsoil and their natural resources, and (b)     the seas and airspace above every area described in paragraph (a). ...