| 19(1) | David R. Senécal |
| (613) 957-2074 | |
| HBW 4125-I7 |
March 26, 1990
Pursuant to your request of March 10, 1990, please find enclosed certain documentation dealing with the recent amendments to the Canada-Italy Tax Convention as they pertain to the tax treatment of pensions paid by the Italian government to residents of Canada. We hope that this information may be useful to you in assisting your clients who are in receipt of Italian pensions.
With respect to your specific enquiry , we are of the view that the term "income" as contained in paragraph 3(a) of Article 1 of the Protocol, refers to income for the taxation year as calculated pursuant to section 3 of the Income Tax Act.
Yours sincerely,
C. Savage A/ DirectorProvincial and International Relations Division
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