Reyes – Federal Court of Appeal finds that Columbia-source government pension was not exempt from Canadian tax

Gauthier JA found that Canada had the clear right under Art. 17 of the Canada-Columbia Convention to tax a former Columbia government employee (now resident in Canada) on a pension from Columbia that was exempt under the Columbia tax laws. The taxpayer lacked good arguments, so he made weak ones.

Neal Armstrong. Summary of Reyes v. Canada, 2019 FCA 7 under Treaties – Income Tax Conventions - Art. 18.