Words and Phrases - "alienation"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

15 October 1997 External T.I. 9713855 - ARTICLE XIII CANADA-ISRAEL TAX TREATY

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 13
alienation includes a deemed disposition under s. 128.1

Canada has the right to tax gains of a taxpayer from the deemed disposition of real property situate in Israel as a result of the taxpayer ceasing to be resident in Canada. "the word 'alienation' ... includes deemed disposition referred to in paragraph 128.8(4)(b) ...".

Words and Phrases
alienation

84 C.R. - Q. 40

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 13
alienation under US treaty includes deemed dispositions

RC accepts the interpretation of "alienation" contained in the Treasury Department's technical explanation, which refers to deemed dispositions under the domestic law.

Words and Phrases
alienation