26 June 1990 Ministerial Correspondence 5901004 F - Pension and Annuity Payments under Canada-Trinidad and Tobago Income Tax Convention

By services, 18 January, 2022
Official title
Pension and Annuity Payments under Canada-Trinidad and Tobago Income Tax Convention
Language
French
CRA tags
n/a
Document number
Citation name
5901004
Severed letter type
Ministerial Correspondence
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631454
Extra import data
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"field_release_date_new": "1990-06-26 08:00:00",
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Main text
24(1) File No. 5-901004
  D.S. Delorey
  (613) 957-3495

Attention: 19(1)

June 26, 1990

Dear Sirs:

Re: Article XIII  Canada-Trinidad and Tobago Income Tax Agreement (the "Trinidad Convention")

This is in reply to your letter of May 28, 1990 concerning the meaning to be given to the terms "pension" and "annuity" for the purposes of Article XIII of the Trinidad Convention.

We note that your enquiry relates to a proposed transaction.  As explained in paragraph 23 of Information Circular 70-6R, the Department does not provide written opinions on proposed transactions other than in reply to advance ruling requests submitted in the manner set out in that Circular.  We offer however the following general comments.

For the purposes of interpreting reciprocal tax conventions, we generally take the view that the term "pension" refers to a payment that is to be made periodically for the life of (or the greater part of the life of; e.g., to age 90) the recipient, unless a definition in a particular treaty dictates otherwise.

With respect to the meaning to be given to the term "annuity" for the purposes of the various reciprocal tax treaties, we have not yet established a general position in this regard.  The matter is presently under consideration.

We trust our comments are of assistance to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate