3 January 2001 Internal T.I. 2000-002424 -
Article 20 of the Canada-New Zealand Convention provides that items of income of a resident of New Zealand which are not dealt with in other Articles and which are derived by the resident from sources in Canada may be taxed in Canada according to the laws of Canada. A gain of a resident of New Zealand from a disposition of shares of a private Canadian corporation that were taxable Canadian property was subject to Canadian capital gains tax given that it had been the intention of the Canadian negotiators of Canadian ncome tax conventions that the source of income on a disposition of taxable Canadian property is from Canada and this intention was confirmed, for greater certainty, by s. 6.3 of the Income Tax Convention Act.
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