Dear Sir:
Re: Canada-Israel Income Tax Convention, 1975 Alimony: Article XVIII(3)(c)
This is in reply to your letter dated April 17, 1991.
We concur with your view that subparagraph 3(c) of Article XVIII of the Canada-Israel Income Tax Convention, 1975 will not exempt alimony paid by a resident of Canada to a resident of Israel from Canadian tax under paragraph 212(1)(f) of the Canadian Income Tax Act if the alimony payments are not taken into account in determining the income of the resident of Israel for Israeli income tax purposes.
Yours truly,
for DirectorReorganization and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch