J. Thompson (613) 957-2127
XXXX
July 24, 1987
INDEXED
Dear Sirs:
Re: Non-Resident Tax - Tax Treaties
This is in reply to your letter of April 21, 1987 and pursuant to a subsequent telephone call to you on May 22, 1987 in relation to the above captioned subject.
As indicated on May 22, 1987 the questions as presented have too many variations and combinations for Revenue Canada to provide a detailed response on the definition of "pensions" as contemplated in every treaty in force between Canada and a foreign country. Moreover, the answer as to what particular type of income falls within the ambit of a given treaty provision under the definition of "Pensions" is to a large extent, dependent on the language and wording in each tax treaty and on the terms and conditions of the plan.
It is our understanding that you agreed to reconsider the alternatives and submit a modified request within two weeks from the date of the telephone call to you on May 22, 1987. Since approximately 60 days have elapsed from the date of our last communication, we regret to inform you that we must close this file.
Yours truly,
for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch