Article 22

Administrative Policy

28 March 2018 External T.I. 2016-0672941E5 - Par. 2 of Norway Other Income treaty Article

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28 July 2015 External T.I. 2014-0522271E5 - REIT Distribution - Article 21 Canada-Sweden Treaty

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20 March 2015 External T.I. 2014-0534301E5 - Canadian Withholding Tax on Retiring Allowance

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(e) - Subparagraph 115(2)(e)(i) retiring allowance paid to non-resident for loss of non-resident employment 54
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(j.1) retiring allowance paid to non-resident for loss of non-resident employment 145
Tax Topics - Treaties - Income Tax Conventions - Article 15 retiring allowance paid to French individual for loss of non-resident employment 71

20 November 2014 Internal T.I. 2014-0539631I7 - Restrictive Covenants-Part XIII (Luxembourg)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56.4 - Subsection 56.4(1) - Restrictive Covenant restrictive covenant definition is broad 90
Tax Topics - Treaties - Income Tax Conventions - Article 7 restrictive covenant payment not eligible for relief under Lux Treaty 138

11 July 2014 External T.I. 2013-0497381E5 - REIT investment in a US IRA.

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 10 SIFT distributions respected as dividends 103

2014 Ruling 2013-0509431R3 - Part XIII tax and distributions from a trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(c) distributions to U.S. residents funded out of ROC payments and cross-border interest 265

13 December 2011 External T.I. 2011-0416261E5 - Article XXII(4) of the Canada-U.S. Treaty

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3 January 2001 Internal T.I. 2000-002424 -

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13 February 1997 T.I. 963271

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3 December 1996 T.I. 963670

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1996 Ruling 960534

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12 April 1995 External T.I. 5-941713 -

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10 March 1995 T.I. 950641 (C.T.O. "Capital Gains - Canada-Australia Treaty (HAA 4093-A3-100)")

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15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 21 22

6 November 1992 T.I. 922332 (September 1993 Access Letter, p. 425, ¶C248-142)

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Articles

David W. Ross, "Withholding Taxes on Retirement Compensation Arrangements", Taxation of Executive Compensation and Retirementl. XIII, No. 2, 2009, p. 801

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David A. Ward, "The Other Income Article of Income Tax Treaties", (1990) 38 Canadian Tax Journal 233 at 268 [quoted approvingly in Black v. The Queen, 2014 DTC 1046 [at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275 at para. 61]

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