29 November 1990 Income Tax Severed Letter

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                                        902713
                                        G. Middleton
                                        (613) 957-2127
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Dear Sirs:

Re: 10% Withholding Tax on Films

This is in reply to your letter of September 20, 1990 concerning the 10% Canadian withholding tax on royalties paid to the

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You questioned whether there is any provision under the Canadian Income Tax Act which provides for an exemption from such tax.

This will confirm that there is no exemption from tax on the film royalties under either the Canadian Income Tax Act or the Canada- United Kingdom Income Tax Convention with respect to payments made by residents of Canada to U.K. charities.

Yours truly,

for Director Reorganizations an Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch