27 June 1990 Ruling HBW4125J1A F - Canada-Japan Income Tax Convention on Residence Status of Charitable Organization

By services, 18 January, 2022
Official title
Canada-Japan Income Tax Convention on Residence Status of Charitable Organization
Language
French
CRA tags
n/a
Document number
Citation name
HBW4125J1A
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633452
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-06-27 08:00:00",
"field_tags": []
}
Main text
24(1) David Senécal
  (613) 957-2074
  HBW 4125-J1

Attention: 19(1)

June 27, 1990

Dear Sirs:

This is further to our letter of March 8, 1990, concerning whether a charitable organization would be considered to be a "resident of a contracting state" for purposes of the residence definition in the tax treaty Canada has with Japan.

The Japanese competent authority has concurred with Canada's position that charitable and other exempt organizations are "residents of a contracting state" for purposes of the Canada-Japan Income Tax Convention.

We trust that this information will be of assistance to you.

Yours sincerely,

Christine SavageActing Director Provincial and InternationalRelations Division

c.c.      Ken Major Foreign Section

DS/jb19(1)File copySequence fileAuthor's copyChrono fileReading file