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19 December 1986 Income Tax Severed Letter 5-2426- [Canada-Switzerland Income Tax Convention] XXXX G. Thornley (613) 957-2130 December 19, 1986 Canada-Switzerland Income Tax Convention (the "Treaty") This is in reply to your letter of October 29, 986 requesting a technical interpretation of the provisions of Article XIII of the above noted treaty in a hypothetical fact situation. ...

Income Tax Convention on Pensions 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. ...

2002 Ruling 2001-0112133- Article XIII of Canada-XXXXXXXXXX Convention Unedited CRA Tags Art. ... Principal Issues: Whether a XXXXXXXXXX is a "property, other than rental property, in which the business of the company... is carried on" for purposes of paragraph 3 of Article XIII of the Canada-XXXXXXXXXX Income Tax Convention. ... DEFINITIONS In this letter, the following terms have the meanings specified: (a) "Act" means the Income Tax Act, R.S.C. 1985, c.1 (5th Supp.), as amended, and all references to a statute are to the Act, unless otherwise indicated; (b) "Agency" means the Canada Customs and Revenue Agency; (c) "arm's length" has the meaning assigned by Section 251; (d) "disposition" has the meaning assigned by section 248(1) of the Act; (e) "Forco1" refers to XXXXXXXXXX; (f) "Forco2" refers to XXXXXXXXXX; (g) "Forco3" refers to XXXXXXXXXX; (h) "FMV" means fair market value; (i) "Holdco" refers to XXXXXXXXXX; (j) "Forco4" refers to XXXXXXXXXX; (k) "Opco" refers to XXXXXXXXXX; (l) "Parentco" refers to XXXXXXXXXX; (m) "Subco" refers to XXXXXXXXXX; (n) "taxable Canadian corporation" has the meaning assigned by subsection 248(1) (which refers to subsection 89(1)); (o) XXXXXXXXXX; (p) "Treaty" refers to the Canada-XXXXXXXXXX Tax Convention. ...

Income Tax Convention on Pension Unedited CRA Tags n/a 19(1) 901544   G. ...

Income Tax Convention Re Withholding Tax on Pensions Unedited CRA Tags none Dear XXX We are writing in follow-up to your telephone conversation on November 23, 1990, with Mr. ...

Income Tax Convention on Pension 19(1) 901544 G. Arsenault (613) 957-2126 19(1) This is in reply to your letter dated July 9, 1990 whereby you enquired concerning a pension paid to you by 24(1) We do not have sufficient information to permit us to express a definitive opinion. ...

10 April 1990 Income Tax Severed Letter ACC9191- Canada-Ireland Income Tax Convention Jim Wilson 19(1) 613-957-2063 HBW 4125-I2 HBW 6591-I2 EACC 9191 April 10, 1990 Dear 19(1) Re: 19(1) We are writing in reply to your letter dated March 5, 1990, concerning the interpretation of the Canada-Ireland Income Tax Agreement (the "Agreement"). ...

8 December 1994 External T.I. 9414455- ARTICLE XXI, PAR.2 OF THE CANADA-U.S CONVENTION Unedited CRA Tags 212(1)(b)(iv) 212(14) 215(1) ART XXI 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(1980) (the "Treaty). This is in reply to your letter dated February 28, 1994 (received by fax in our office on June 3, 1994) wherein you asked us to confirm that the interest payments made by employees resident of Canada to certain retirement plans resident in the United States would be exempt from Canadian withholding tax under Part XIII of the Income Tax Act (the "Act"), by virtue of Article XXI, paragraph 2 of the Treaty. ...

Income Tax Convention (1980) Unedited CRA Tags 20(1)(v.1), Canada–U.S. Tax Convention Canada-U.S. Tax Treaty:Art. VI, XIII This memorandum is in response to yours of June 27, 1989 in which you requested our opinion concerning the characterization of property as real property situated in Canada which, upon alienation by a resident of the United States, can result in a taxable gain in Canada pursuant to Article XIII of the Treaty. ...

16 January 1990 Income Tax Severed Letter ACC8919- Canada-Netherlands Income Tax Convention- Pension of Public Employees January 16, 1990 Provincial and International Relations Division J. ... Solley Manager, Public Affairs Penticton District Office 19(1) Canada-Netherlands Tax Convention Article 18 We are writing in reply to your memorandum dated July 27, 1989, concerning the above-noted taxpayer. ...