The North West Life Assurance Company of Canada - Page 60

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            1949, 1990-2 C.B. 274.21  We have considered all of the other                              
            arguments made by respondent and, to the extent we have not                                
            addressed them, find them to be without merit.                                             
                                                            Decision will be entered                   
                                                      for petitioner.                                  


                  Reviewed by the Court.                                                               
                  COHEN, CHABOT, JACOBS, GERBER, PARR, WELLS, WHALEN, BEGHE,                           
            LARO, and VASQUEZ, JJ., agree with this majority opinion.                                  
                  CHIECHI, J., did not participate in the consideration of                             
            this opinion.                                                                              
















            21Art. 7(7) of the U.S.-New Zealand Convention includes a                                  
            provision regarding the taxation of permanent establishments of                            
            insurance companies.  This provision provides:                                             
                  Nothing in this Article shall prevent either                                         
                  Contracting State from taxing according to its law the                               
                  income or profits from the business of any form of                                   
                  insurance. [Tax Convention, July 23, 1982, U.S.-N.Z.,                                
                  35 U.S.T. (Part 2) 1949, 1964.]                                                      




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