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Income Tax Convention in light of s. 45(2) of the Interpretation Act. ...

Income Tax Convention did not include made-for-television movies or other television productions in light of evidence that this was how the phrase "motion-picture-film" was interpreted in the industry. ...

Convention was interpreted contrary to the position of the Minister in light of the Technical Explanation of the U.S. ...

Convention was contrary to section 15 of the Charter in light of the citizenship preference contained in paragraph 8 of Article XXVI A. ...

MNR, 79 DTC 5394, [1979] CTC 459 (FCA)-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 Canadian real estate dealings of the U.S. ...

.)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 A Jersey partnership comprising over 100 U.K. resident partners and carrying on a trade which was managed and controlled in Jersey, was a body of persons resident in Jersey rather than in the U.K. in the context of the provisions before the English court. ...

The Queen, 2001 DTC 781 (TCC) (Informal Procedure)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 A disability pension received by the taxpayer from the United Steelworkers of America as a result of group term life insurance provided by them was exempt from tax under the Act in light of evidence that the payments were exempt under the Internal Revenue Code. ...

MNR, 86 DTC 1327, [1986] 1 CTC 2449 (TCC)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Canadian counsel of the taxpayer did not constitute a permanent establishment because he could not commit himself on behalf of his client unless specifically authorized by a document to do so. ...

The Queen, 2005 DTC 1109, 2005 TCC 366-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Given the depth of her roots in South Korea, the taxpayer's centre of vital interests was in South Korea rather than Canada. ...

Income Tax Convention. ...