0-0318
Subject: Reciprocal Tax Treaties Meaning of "Periodic Payment"
This relates to our memorandum dated November 16, 1989 (copy attached), to which we received your interim reply dated February 14, 1991, and is further to the meeting of February 28 attended by the following:
C. B. Darlingng D. Delorey W. Douglas K. Harding C. Savage David R. Senécal
As agreed, attached is a copy of our memorandum to the Non-Resident Taxation Division reflecting the general positions decided upon at the above meeting.
Director GeneralRulings DirectorateLegislatives and Intergovernmental Affairs Branch