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(x) "taxation year" has the meaning assigned by subsection 249(1), in respect of any taxpayer referred to herein which is a corporation, and the meaning assigned by paragraph 96(1)(b), in respect of the Partnership; and (y) "Treaty" means the XXXXXXXXXX Income Tax Convention, XXXXXXXXXX. ...

The adjusted cost base, paid-up capital, stated capital and redemption amount of the XXXXXXXXXX Class D Shares are $XXXXXXXXXX. 10.1 If the shares of XXXXXXXXXX owned by XXXXXXXXXX were disposed of on the date of this letter by XXXXXXXXXX, any resulting gain would be exempt from tax under the Act by virtue of Article XIII of the Canada- United States Income Tax Convention, 1980. ...

For taxation years prior to XXXXXXXXXX has also been a resident of the United States, but has historically filed personal returns in Canada on the basis that the provisions of the Canada-United States Income Tax Convention resolve his residency in favour of Canada. 2. ...

Ce sont les conventions fiscales avec les pays qui régissent les échanges d'information. ...

(a)     We are of the opinion that the issuance and receipt of the IDU Bonds was not a payment of interest for purposes of the Canada  — XXXXXXXXXX Income Tax Convention (the "Treaty").       ...

A cette fin, X respectera la convention collective signée par Y et ses anciens employés. ...

Income Tax Convention?-------------------------- There is no deeming provision which determines for purposes of the Indian Act exemption how income should be allocated among various locations. ...

Des conventions de renouvellement de consignation en date du XXXXXXXXXX nous ont été fournies. ...

The indebtedness is a demand note with interest rate at prime plus XXXXXXXXXX% reset annually on XXXXXXXXXX; (f) "carrying on business" has its extended meaning as stated in subsection 253(1); (g) "CBCA" means the Canada Business Corporations Act; (h) "the Code" means the United States Internal Revenue Code of 1986; (i) "corporation" has the meaning assigned by subsection 248(1); (j) "cumulative taxable income" has the meaning assigned by subsection 133(9); (k) "FMV" means fair market value; (l) "non-resident-owned investment corporation" has the meaning assigned by subsection 133(8); (m) XXXXXXXXXX; (n) "PUC" means paid up capital as defined in subsection 89(1); (o) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); and (p) "the Treaty" means the Canada-United States Income Tax Convention. ...

Dans cette cause, les employés étaient régis par des conventions collectives en vertu desquelles les employés gagnaient leurs vacances pendant la période de référence qui se situait entre le 1e mai et le 30 avril de chaque année. ...