d) annuities arising in a Contracting State and paid to a resident of the other Contracting State may also be taxed in the State in which they arise and according to the law of that State, but the tax so charged shall not exceed fifteen per cent of the portion thereof that is subject to tax in that State; however, this limitation does not apply to lump-sum payments arising on the surrender, cancellation, redemption, sale or other alienation of an annuity, or a payment of any kind under an annuity contract the cost of which was deduct ...[+++]ible, in whole or in part, in computing the income of any person who acquired the contract.

“This contract witnesseth further that in consideration of the payment of premiums in any other manner than above indicated, such annuity shall be paid at the date of maturity of this contract as such premiums will purchase according to the rates of mortality and interest in effect on the date of inclusion of the annuitant under the Group Annuity Contract, provided, however, that the total annuity payable to the Annuitant hereunder and under any other ...[+++]Canadian Government Annuity Contracts shall not exceed $1,200 per year”

3. A Preexisting Individual Account that is a Cash Value Insurance Contract or an Annuity Contract, provided the law or regulations of Canada or the United States effectively prevent the sale of such a Cash Value Insurance Contract or an Annuity Contract to U.S. residents (e.g., if the relevant Financial Institution does not have the required regist ...[+++]ration under U.S. law, and the law of Canada requires reporting or withholding with respect to insurance products held by residents of Canada).

(b) An annuity or other amount paid in respect of a life insurance or annuity contract (including a withdrawal in respect of the cash value thereof) shall be deemed to arise in a Contracting State if the person paying the annuity or other amount (in this subparagraph referred to as the “payer”) is a resident of that State.

(2) In determining the amount that shall be included in computing the income of a taxpayer in respect of payments received by the taxpayer in a taxation year under annuity contracts entered into after May 25, 1932, and before June 25, 1940, with the Government of Canada or annuity contracts like those issued under the Government Annuities Act entered into during that period with the government of a province or a corporation incorporated or licensed to carry on an annuities business in Canada, there may be deducted from the total of the payments received the lesser of

The term also includes a contract that is considered to be an Annuity Contract in accordance with the law, regulation, or practice of the jurisdiction (being a Member State, Liechtenstein or other jurisdiction) in which the contract was issued, and under which the issuer agrees to make payments for a term of years.