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Tax Conventions] G. Thornley (613) 957-2130 November 18, 1986 Dear Sir: Re: Canada-U.S. Tax Conventions This is in reply to your letter of August 25, 1966 concerning the taxation of world wide income of Canadians who are deemed residents of the United States. ...

Income Tax Convention (1980) (the "Treaty") and Partnerships] Revenue Canada Taxation Head Office XXX J. ... Income Tax Convention (1980) (the "Treaty") and Partnerships This is in response to your letter dated November 6, 1991 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

22 January 1990 Income Tax Severed Letter ACC8916- Canada-Finland Income Tax Convention- Social Security Pensions from Finland 19(1) HBW 4125-F1 Jim Wilson (613) 957-2063 January 22, 1990 Dear 19(1) We are writing in regards to the tax treatment of Finnish social security pensions paid to residents of Canada. We have recently received enquiries as to whether social security pensions from Finland meet the definition of "pension" or "annuity" under Article II of the Canada-Finland Income Tax Convention (1958). ...

Income Tax Convention (1980) (the "Treaty", and, Partnerships] Revenue Canada Taxation Head Office O. ... Income Tax Convention (1980) (the "Treaty") and Partnerships This is in response to your letter dated December 22, 1989 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

Pour qu'il y ait un avantage en vertu de l'alinéa 7(1)a) de la Loi, l'employé doit avoir acquis des actions en vertu d'une convention lui permettant de les acquérir. ... Selon les faits que vous nous avez fournis, nous sommes d'avis que le contribuable a acquis les actions en vertu d'une convention visée par l'alinéa 7(1)a) de la Loi. ... Une convention peut prévoir la détention des actions en fiducie, conditionnellement ou non, pour le compte d'un employé jusqu'à ce que certaines conditions soient remplies. ...

16 June 2010 Roundtable, 2010-0369271C6- Canada-US Tax Convention- Treatment of LLCs Unedited CRA Tags Article IV of the Canada-US Tax Convention Principal Issues: Impact of the Tax Court of Canada decision in TD Securities (USA) LLC Position: See response Reasons: See response CANADIAN PETROLEUM TAX SOCIETY 2010 ANNUAL CONFERENCE TD Securities (USA) LLC Decision On April 8, 2010, the Tax Court of Canada rendered its judgment in TD Securities (USA) LLC v. ... (endnote 1) The Court concluded that TD Securities (USA) LLC, a limited liability company ("LLC") formed under United States law, was entitled to benefits under the Canada-United States Tax Convention (1980) (the "Treaty"). ...

7 November 1987 Income Tax Severed Letter RRRR120- Information Circular 76-12R3 Footnote (6) Canada-Norway Income Tax Convention Unedited CRA Tags 212(1)(d) As discussed with you in a recent telephone conversation, we suggest that you consider amending Information Circular 76-12R3 to clarify the Department's position on the rate of withholding tax that applies to rental income from moveable property received by a resident of Norway from a resident of Canada. ...

Income Tax Convention on Pensions Unedited CRA Tags n/a 19(1) Jim Wilson   (613) 957-2063   HBW 4000-3 April 30, 1990 Dear 19(1) We are writing in regards to your letter dated April 14, 1990, concerning the tax treatment of certain pensions upon immigration to Canada. Pursuant to Article 18 of the Canada-United States Income Tax Convention, pensions (other than benefits received under U.S. social security legislation or pensions that would otherwise be exempt form U.S. tax if you remained a resident thereof) arising in the United States and paid to a resident of Canada (i.e. you would be considered a resident of Canada upon immigration) may be taxed in both countries.  ...

Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. ...

Income Tax Convention] MEMORANDUM March 10, 1983 TO Provincial and International Relations Division Mr. ... Income Tax Convention (1978) (the "Treaty") We enclose the letter dated December 20, 1982 from XXXX concerning the above-mentioned Treaty and its application to a repurchase of shares by a U.K. corporation from an individual shareholder who is resident in Canada or from a corporate shareholder which is resident in Canada and owns less than 10% of the voting power of the U.K. corporation. ...