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Volume #12 - 1153.

CHAPTER XII

RELATIONS WITH INDIVIDUAL COUNTRIES

PART 8

FRANCE

1153.

DEA/8326-40

Secretary of State for External Affairs
to Ambassador in France

TELEGRAM 126

IMMEDIATE.

Ottawa, April 4th, 1946

1. French delegation on double taxation having advanced its schedule arrived here last night from Washington. Negotiations began this morning. As Deputy Minister of National Revenue is away and as French delegation staying only until April 6 discussions aim merely at reaching agreement in principle with final negotiations to be concluded at a later date in Paris or by correspondence. Discussions will deal with proposed convention for the avoidance of double taxation on income and for the avoidance of double succession duties. Convention will probably closely follow the Canada-United States Income Tax Convention of 19422 with the exception that provisions for exchange of information are not as complete. The succession duties convention will probably follow fairly closely the Canada-United States Convention of 19443

We intend to seek the retroactive application of the income tax convention to cover disputed cases of Royal Bank, etc. under French decree of 1872.

We hope to discuss also the national solidarity tax and the treatment of Canadian interests under French laws respecting reconstruction grants to war damaged properties although we do not expect to make much progress on these points since they are unrelated to the main purpose of the talks.

4. If there are further general questions or particular points which you feel we might raise we would be glad to hear from you immediately.



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