U.S.-Canada Income Tax Treaty definition

U.S.-Canada Income Tax Treaty means the Convention Between the United States of America and Canada with Respect to Taxes on Income and Capital, dated as of September 26, 1980, as amended.
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Examples of U.S.-Canada Income Tax Treaty in a sentence

  • An interesting glimpse as to the effects of those bilateral income tax treaties on International philanthropy might be gleaned from the U.S.-Canada Income Tax Treaty, and its recent amendment by the Fifth Protocol that entered into force on December 15, 2008 (the “Protocol”).

  • The Protocol was intended to resolve certain discrepancies in the existing U.S.-Canada Income Tax Treaty with respect to cross-border charitable bequests, however, it has potentially created the exact opposite effect.

  • Currently there are only three such U.S. income tax treaties – the U.S.-Israel Income Tax Treaty, the U.S.-Mexico Income Tax Treaty, and the U.S.-Canada Income Tax Treaty (the “Treaty”).

  • The third and final part of this paper will address how bilateral income tax treaties can alter these rules pertaining to cross-border charitable activities, and will look specifically at the potential discrepancies created by the Fifth Protocol to the U.S.-Canada Income Tax Treaty that was adopted on December 15, 2008.

  • The question then arises as to whether the Claimant made a protected disclosure to the Respondent.

  • At the same time, Canada would tax the gain because, under the U.S.-Canada Income Tax Treaty, gain attributable to real property may be taxed in the country where the real property is located.11 Thus, if no treaty relief was available, double taxation would occur.

  • When a non-IOP surgical procedure is performed on an in-patient by a physician other than the attending physician, the fee payable includes post-operative care for 14 days in hospital.

  • This is an updated version of the same article previously pub- lished by the American Bar Association in 2013.We begin with a review of the U.S. and Canadian taxes applicable at death, in addi- tion to the U.S.-Canada Income Tax Treaty (the “Treaty”) which covers both income and estate taxes.5 BACKGROUND OF U.

  • Payment of the Exercise Price shall be by any of the following, or a combination of the following, at the election of Optionee: (a) cash, (b) check, (c) Cashless Exercise, or (d) surrender of previously owned Shares.

  • Subject to the limitations set forth in the U.S. Internal Revenue Code, as modified by the U.S.-Canada Income Tax Treaty, U.S. Holders may elect to claim a foreign tax credit against their U.S. federal income tax liability for Canadian income tax withheld from dividends.

Related to U.S.-Canada Income Tax Treaty

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • Foreign Income Tax means any Tax imposed by any foreign country or any possession of the United States, or by any political subdivision of any foreign country or United States possession, which is an income tax as defined in Treasury Regulation Section 1.901-2, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • tax treaty means an agreement for the avoidance of double taxation entered into between South Africa and another country;

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • U.S. Tax Code means the United States Internal Revenue Code of 1986, as amended.

  • Non-Income Tax means any Tax other than an Income Tax.

  • Australian Tax Act means the Income Tax Assessment Act 1936 (Cth) (Australia) or the Income Tax Assessment Act 1997 (Cth) (Australia), as applicable.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Canadian Tax Act means the Income Tax Act (Canada), as amended.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Transaction Tax Deductions means any Tax deductions relating to (i) the Company Transaction Expenses, and (ii) repayment of the Indebtedness, including any unamortized deferred financing fees in connection with the Indebtedness.

  • foreign tax means any Foreign Income Taxes or Foreign Other Taxes.

  • Intended Tax Treatment has the meaning specified in the Recitals hereto.

  • Tax Treatment [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]

  • Qualifying tax rate means the applicable tax rate for the taxable year for the which the taxpayer paid income tax to a municipal corporation with respect to any portion of the total amount of compensation the payment of which is deferred pursuant to a nonqualified deferred compensation plan. If different tax rates applied for different taxable years, then the “qualifying tax rate” is a weighted average of those different tax rates. The weighted average shall be based upon the tax paid to the municipal corporation each year with respect to the nonqualified deferred compensation plan.

  • Swiss Withholding Tax Act means the Swiss Federal Act on Withholding Tax of 13 October 1965 (Bundesgesetz über die Verrechnungssteuer), together with the related ordinances, regulations and guidelines, all as amended and applicable from time to time.

  • Incremental income tax means the total amount withheld

  • PAYEE TAX REPRESENTATIONS Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • U.S. Tax Person means a Person that is a “United States person” as defined in Section 7701(a)(30) of the Code, generally including:

  • Federal Income Tax means any Tax imposed by Subtitle A of the Code, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • United States Tax Person A citizen or resident of the United States, a corporation, partnership or other entity created or organized in, or under the laws of, the United States, any State thereof or the District of Columbia, an estate whose income from sources without the United States is includible in gross income for United States federal income tax purposes regardless of its source or a trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more United States Tax Persons have the authority to control all substantial decisions of the trust, all within the meaning of Section 7701(a)(30) of the Code (or, to the extent provided in the applicable Treasury Regulations, certain trusts in existence on August 20, 1996 that have elected to be treated as United States Tax Persons).

  • UK Tax Deduction means a deduction or withholding for, or on account of, Tax imposed by the United Kingdom from a payment under a Loan Document, other than a FATCA Deduction.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.