Section 3
Cases
Beame v. Canada, 2004 DTC 6103, 2004 FCA 51
Article VI of the Canada-Ireland Convention, which provided that "the rate of Canadian tax on income ... derived from sources within Canada by a...
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| Tax Topics - Treaties - Income Tax Conventions - Article 2 | 123 |
Section 4.3
Administrative Policy
11 October 2013 Roundtable, 2013-0492821C6 F - Question 3 - APFF Round Table
After noting the introduction of s. 4.3, CRA stated:
[T]he effect of this new provision is to make it impossible to break the tie [under the...
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| Tax Topics - Treaties - Income Tax Conventions - Article 4 | s. 94 trusts were resident in Canada for Treaty purposes even before Income Tax Conventions Interpretation Act amendment, which precludes application of tie-breaker | 339 |
Section 5
Administrative Policy
6 April 2023 Internal T.I. 2022-0929731I7 - Articles 18(2) and (3) of the Canada-Italy Treaty
Regarding the receipt by an individual resident in Italy of periodic Canada Pension Plan (“CPP”) and Old Age Security (“OAS”) benefit...
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| Tax Topics - Treaties - Income Tax Conventions - Article 18 | CPP and OAS payments treated as pensions and social security payments under the Canada-Italy Treaty | 155 |
Pension
Administrative Policy
30 March 2017 External T.I. 2015-0609951E5 F - Article 18 of the Canada-Turkey Income Tax Convention
RRSP annuity payments made to a resident of Turkey were deemed by s. 5 to be pension payments (as “pension” was not specifically defined in...
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| Tax Topics - Treaties - Income Tax Conventions - Article 18 | capital portion of s. 56(1)(d) is not excluded as an annuity under Canada-Turkey Treaty/RRSP annuity payments are pensions | 428 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(d) | capital components are not deduction of cost | 126 |
Paragraph (a)
Subparagraph (a)(ix)
Administrative Policy
23 August 2001 External T.I. 2001-0086235 F - CONVENTIONS FISCALES A.18
Regarding the tax treatment of QPP and OAS payments made to residents of Slovenia, CCRA indicated that under the Slovenia Convention, since...
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| Tax Topics - Treaties - Income Tax Conventions - Article 18 | QPP and OAS were pension payments made under social security legislation for purposes of the Slovenia and Croatia treaties | 240 |
Periodic Pension Payment
Administrative Policy
12 September 2019 External T.I. 2017-0732681E5 - Payment of pension surplus to US resident beneficiary
The U.S.-resident beneficiary of her deceased mother’s individual pension plan (IPP) received monthly benefits thereunder that were eligible for...
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| Tax Topics - Treaties - Income Tax Conventions - Article 18 | Reg. 8503(26) minimum amount payments or commutation payments are lump sums ineligible for reduction under Canada-U.S. Treaty | 307 |
Section 6.2
Administrative Policy
3 January 2001 Internal T.I. 2000-0024247 - Section 6.2 of Income Tax Convention
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...
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| Tax Topics - Treaties - Income Tax Conventions - Article 22 | 130 |