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31 January 1990 Income Tax Severed Letter ACC89806- Canada-Germany Income Tax Convention David Senecal (613) 957-2074 HBW 6591-G1 HBW 4125-G1 January 31,1990 Mr. 19(1) Re: Exchange of Information under the Canada-Germany Income Tax Convention (1956) 19(1) Following your request dated November 14, 1989, we have attempted to obtain the information required. ...

Income Tax Convention on Dividend Payments Unedited CRA Tags 258(3), 113 24(1) 5-9470   G. Arsenault   (613) 957-2126 Attention: 19(1) August 31, 1990 Dear Sirs: Re:  Subsection 258(3) This is in reply to your letter dated January 26, 1990 whereby you requested that we provide our opinion as to the application of  subsection 258(3) of the Income Tax Act (Canada) (the "Act") and Article 21(1)(b) of the Canada-United Kingdom Income Tax Convention (the "Treaty") in respect of dividends (the "TPS Dividends") paid by a corporation resident in the United Kingdom (the "Foreign Affiliate") to a Canadian resident specified financial institution (the "SFI") on term preferred shares of the Foreign Affiliate acquired by the SFI in the ordinary course of the business carried on by it, such term preferred shares constituting all of the shares of a class of preference shares in the capital stock of the Foreign Affiliate. ... By virtue of paragraph 3(2) of the Treaty and Section 3 of the Income Tax Conventions Interpretation Act, to the extent a term used in the Treaty is not defined therein, it has the meaning it has under the laws of (Canada) relating to the taxes which are the subject of the Treaty.  ...

27 July 1990 Income Tax Severed Letter ACC9379- Canada-Australia Income Tax Convention on Capital Gains July 27, 1990 FROM- Rulings Directorate G. ... Calderwood Director SUBJECT: 24(1) Canada-Australia Income Tax Convention This is in reply to your Memorandum dated June 18, 1990 whereby you requested our opinion as to whether residents of Australia are exempt from Canadian tax liability in respect of capital gains realized on the disposition of taxable Canadian property, particularly shares in the capital stock of a corporation resident in Canada (other than a public corporation), by virtue of the Canada-Australia Income Tax Convention (1980) (the "Treaty"). ...

26 February 1990 Income Tax Severed Letter ACC8843- Canada-USSR Income Tax Convention on Interest Payments Unedited CRA Tags Canada-USSR Income Tax Convention EACC8843 19(1) Jim Wilson (613) 957-2063 HBW 4125-U2 HBW 6591-U2 February 26, 1990 Dear 19(1) Re: 24(1) I am writing in reply to your letter dated November 21, 1989, concerning the tax status in Canada of the above-noted institution. ... Income Tax Convention, interest arising in one of the Contracting States and paid to a resident of the other Contracting State is taxable only in that other State where paid to parties described in subparagraphs (a), (b) or(c). ...

Income Tax Convention Unedited CRA Tags 212(1)(q) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... INCOME TAX CONVENTION Section(s): 212(1)(q)] January 9, 1992 International Tax Programs Financial Industries Directorate Division D. ... As we mentioned to you however during our (Douglas/Power) recent telephone conversation, a payment under a RRIF that is otherwise a periodic pension payment could be disqualified as such if proposed amendments to the Income Tax Conventions Interpretation Act are enacted as proposed. ...

7 February 1991 Income Tax Severed Letter- Income Tax Convention with Australia Unedited CRA Tags Canada-Australia Income Tax Convention Dear XXX We have received your facsimile transmission of November 2, 1990. ... The tax convention with Australia stipulates in Article 7 that the profits of an enterprise of one state shall only be taxable in the other if it carries on business there through a permanent establishment situation therein. ...

Income Tax Convention NOV- 2 1989 International Audits Division Specialty Rulings S.K. ... Income Tax Convention (1980) (the "new treaty") Canada-U.S. Income Tax Convention (1942) (the "old treaty") This is in response to your memorandum of June 9, 1989. ...

Income Tax Convention on Dividend Payments 5-9470 G. Arsenault (613) 957-2126 24(1) Attention: 19(1) August 31, 199O Dear Sirs: Re: Subsection 258(3) This is in reply to your letter dated January 26, 1990 whereby you requested that we provide our opinion as to the application of subsection 258(3) of the Income Tax Act (Canada) (the "Act") and Article 2l(l)(b) of the Canada-United Kingdom Income Tax Convention (the "Treaty") in respect of dividends (the "TPS Dividends") paid by a corporation resident in the United Kingdom (the "Foreign Affiliate") to a Canadian resident specified financial institution (the "SFI") on term preferred shares of the Foreign Affiliate acquired by the SFI in the ordinary course of the business carried on by it, such term preferred shares constituting all of the shares of a class of preference shares in the capital stock of the Foreign Affiliate. ... By virtue of paragraph 3(2) of the Treaty and Section 3 of the Income Tax Conventions Interpretation Act, to the extent a term used in the Treaty is not defined therein, it has the meaning it has under the laws of (Canada) relating to the taxes which are the subject of the Treaty. ...

Income Tax Convention 24(1) 900875 G. Aresenault Attention: 19(1) August 30, 1990 Dear Sirs: Re: Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your reply to your letter dated may 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

Un employé peut-il renoncer à l'indemnité de départ et l'employeur peut-il verser un montant équivalent dans une convention de retraite? ... L'employeur et le fiduciaire conviendront que FIDUCIE constituera une convention de retraite au sens du paragraphe 248(1) et une fiducie de convention de retraite telle que définie au paragraphe 207.5(1) de la Loi et le fiduciaire sera le dépositaire des fonds. 28. ... Le fiduciaire s'engagera à respecter les engagements fiscaux prévus à la Loi dans le cas des conventions de retraite. 46. ...