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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. ...

Income Tax Convention as "a stated sum payable periodically at stated times during life. ...

Expense- Know-How and Training Expenses incurred by the taxpayer, an Amway distributor, in attending "business training seminars" (characterized by the court as conventions) in Canada and the U.S. were found to be on capital account given that "the acquisition of new skills and increased knowledge by the attendees forms an integral part of those seminars" (p. 2119). ...

Expense- Lessening of Competition Expenses incurred by the taxpayer, an Amway distributor, in attending "business training seminars" (characterized by the court as conventions) in Canada and the U.S. were found to be on capital account given that "the acquisition of new skills and increased knowledge by the attendees forms an integral part of those seminars" (p. 2119). ...

Tekmark Global Solutions LLC (2010), 38 SOT 7 (Mumbai ITAT)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 no services provided through seconded employees As a U.S. resident (" Tekmark") had provided personnel only to work under the control and supervision of a resident of India ("Lucent") and did not render any technical services to Lucent through these personnel, the deputation of such personnel did not create a services PE. ...

The Queen, 78 DTC 6368, [1978] CTC 528 (FCTD), aff'd 82 DTC 6071, [1982] CTC 64 (FCA)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 The German plaintiff owned and managed property in Hamburg that contained 17 rented apartments, and he was a shareholder in a public company that operated residential properties in West Berlin. ...

Income Tax Convention. ...

The Queen, 94 DTC 6059, [1994] 1 CTC 28 (FCA)-- summary under Article 20 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 20 The taxpayer, a Chinese citizen, entered Canada on a visitor's visa in 1984, and in 1987 married a Canadian citizen and applied for landed immigrant status. ...