Treaties

Table of Contents

Cases

Crown Forest Industries Ltd. v. The Queen, 92 DTC 6305 (FCTD)

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Utah Mines Ltd. v. The Queen, 92 DTC 6194 (FCA)

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National Corn Growers Assn. v. Canada (Import tribunal), [1990] 2 S.C.R. 1324

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See Also

Trieste v. The Queen, 2012 DTC 1125 [at 3133], 2012 TCC 91, aff'd 2012 FCA 320

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Sommerer v. The Queen, 2011 DTC 1162 [at 845], 2011 TCC 212, aff'd 2012 FCA 207

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Hinkley v. MNR, 91 DTC 1336 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 14 76

Articles

Michael N. Kandev, Matthew Peters, "Treaty Interpretation: The Concept of 'Beneficial Owner' in the Canadian Tax Treaty Theory and Practice", Canadian Tax Foundation, 2011 Conference Report, 26:1-60

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 11 392

Craig Elliffe, "Cross Border Tax Avoidance: Applying the 2003 OECD Commentary to Pre-2003 Treaties", British Tax Review, No. 3, 2012, p. 307

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David A. Ward, "Principles to be Applied in Interpreting Tax Treaties", 1977 Canadian Tax Journal, p. 263.

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Tax Topics - Treaties 0