Income Tax Conventions Interpretation Act

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

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

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