“Under the Intergovernmental Agreement, Canadian banks will attempt to: Notwithstanding Articles XIV (Independent Personal Services) and XV (Dependent Personal Services), an amount paid by a resident of one State party to a residence in the other contracting state may be paid to a resident of the other State party to sign an agreement on the provision of an athlete`s services (with an amount under paragraph 1 of Article XV) Services to the person). , in the first state. but the tax thus collected must not exceed 15% of the gross amount of this payment. 4. When an estate, trust or other person (except for a person or corporation) is established in the two contracting states under paragraph 1, the competent authorities of the States agree to clarify the matter and determine the nature of the application of the agreement to that person. 7. The bond exchange between the United States and Canada was terminated on August 2 and September 17, 1928, which exempted the double-rate taxation of ship profits. Its provisions expire for fiscal years beginning January 1 or after the effective date of this Convention. (5) If a person was established in the United States immediately prior to the person`s death, within the meaning of section 70, paragraph 6, of the Income Tax Act, the individual`s person and spouse are considered to be residing in Canada immediately prior to the person`s death. If a trust, which would be a trust covered by Section 70, paragraph 6, of this Act, if its directors, residents or citizens of the United States or national entities were domiciled in accordance with U.S. law, has asked Canada`s competent authority to do so, Canada`s competent authority may, subject to the conditions satisfactory to that competent authority.
All right. to treat the trust within the meaning of this Act so that it is established in Canada for the implementation of the agreement. 8. Foreign residents of a State party Ownership of a corporation or other organization, reorganization, merger, division or other transaction and benefit, profits or similar income relating to such alienation is not recognized for the purposes of taxation in that state, if the person acquiring the estate is invited to do so, the competent authority of the other contracting state may give its consent in order to avoid double taxation and to have conditions of double taxation. which are satisfactory for this competent authority to defer until that date and according to the terms provided by the agreement the recognition of the benefit, profit or income of these assets with respect to these assets for the purposes of taxation in that other state.