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In French; Le terme “valeurs mobilières” désigne une classe d’actifs qui comprend, par convention, les actions de sociétés, les intérêts dans des sociétés par actions, les titres de créance comme les obligations et les instruments financiers dérivé ….” ...

(k)            The sales effort started with advertisement in the London Free Press leading to the public meeting at the London Convention Centre or high school with a nationally known figure in the investment community- Brian Costello. ...

Relevant Legislation:   [80]     An exemption from payment of income tax is found in paragraph 81(1)(a) of the ITA:   81.(1) – There shall not be included in the computing the income of a taxpayer for a taxation year,   (a) – an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada;   [81]     Paragraph 87(1) of the Indian Act provides for a declaration of exemption as follows:   87(1) – Notwithstanding any other Act of the Parliament or any Act of the legislature of a province, but subject to section 83 and section 5 of the First Nations Fiscal and Statistical Management Act, the following property is exempt from taxation, namely:   […] (b)     the personal property of an Indian or a band situated on a reserve.   ...

Paragraph 87(1)(a) is applied through paragraph 81(1)(a) of the Income Tax Act, which reads:    81(1) There shall not be included in computing the income of a taxpayer for a taxation year,   (a) an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada;   Analysis   The connecting factors test   [89]          In Williams, (supra), the Supreme Court established the connecting factors test to determine the situs of intangible personal property for the purpose of section 87 of the Indian Act. ...

Prior to that, Bornn had been employed as a Sales Manager for a national ice-cream company and had also worked in the hotel convention industry. ...

It was therefore reasonable to believe that they may have been distrustful, especially since they were not familiar with the language or the customs and conventions of their new host country. [206]    Of course, hiding substantial amounts of money at one’s home or the place of business one is associated with is not sufficient to justify the imposition of penalties under subsection 163(2) of the Income Tax Act. [207]    Indeed, this may be a question of distrust or culture. ...

(iv) communique un sommaire des conventions relatives aux honoraires et débours qui sont intervenues entre lui et l’avocat inscrit au dossier. ...

La situation en l’espèce n’est pas plus troublante que celle de l’arrêt Dell, où la Cour suprême du Canada a conclu qu’un consommateur était lié par une convention d’arbitrage affichée sur un site Web et que le consommateur avait omis de lire. ...

See Exhibits A-7, A-8, A-9 and A-10. [82] A naming convention for Partnercos and Servicecos was adopted under which the Principal’s profession was part of the name. ...

In the appellant’s counsel written submissions it is stated that the one- day trip to Boston was in connection with a brewery convention. ...