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Indeed, she did not recall what convention she attended but she suggested it may have been in the United States. ... Concerning conventions and seminars: "Conventions are expensive". 4. ... She has been updating her knowledge through seminars and conventions, although the specifics are uncertain. ...

Drouin Deputy Attorney General of Canada Ottawa, Canada     [1] Exhibit R-1: Annual statements (English translation); Exhibit R-2: Annual statements (in Dutch). [2] Amended Reply to the Notice of Appeal, paragraph 10. [3] Amended Reply to the Notice of Appeal, paragraph 13(g). [4] Convention Between Canada and the Kingdom of the Netherlands, Article 2, paragraph 3. [5] Convention Between Canada and the Kingdom of the Netherlands, Article 18, paragraphs 1 and 2. [6] Convention Between Canada and the Kingdom of the Netherlands, Article 22, paragraph 5(a). [7] Income Tax Act, subsection 126(1). [8] Convention Between Canada and the Kingdom of the Netherlands, Article 22, paragraph 6(b). [9] Income Tax Act, subparagraph 56(1)(a)(i). [10] Béliveau v. The Queen, 2018 TCC 87 at paragraphs 14, 22, and 24. [11] Exhibit R-2: Annual statements (in Dutch). [12] Exhibit R-1: Annual statements (English translation). [13] Convention Between Canada and the Kingdom of the Netherlands, Article 22, paragraph 6(b). [14] Amended Reply to the Notice of Appeal, paragraph 13. ...

Indeed, she did not recall what convention she attended but she suggested it may have been in the United States. ... Concerning conventions and seminars: “Conventions are expensive”. 4. Concerning depreciation: “Probably my computer”. 5. ... She has been updating her knowledge through seminars and conventions, although the specifics are uncertain. ...

The Canada-U.S. 1942 Tax Convention is the tax convention relevant to the case at hand. The Canada-U.S. 1942 Tax Convention was adopted, approved and incorporated into the domestic tax laws of Canada by the Canada United States of America Convention Act, 1943, 7 George VI, c. 21. ... Tax Convention. Walsh, J. noted that the Federal Court has the right to interpret the Canada-U.S. ...

Reasons for Judgment Watson, D.J.T.C.C. [1]            This appeal was heard in Bathurst, New Brunswick, on June 29, 2001. [2]            The Appellant's income tax returns for the 1996 and 1997 taxation years were originally assessed on April 21, 1997 and March 16, 1998 respectively. [3]            In computing his non-refundable tax credits for the 1996 and 1997 taxation years, the Appellant included an equivalent-to-spouse amount in respect of his children. [4]            By notices of reassessment dated March 25, 1999, the Minister of National Revenue (the "Minister") advised the Appellant that he had been denied the equivalent-to-spouse amount for these two taxation years. [5]            In reassessing the Appellant, the Minister made the following assumptions of fact: a)              the Appellant and his former spouse were divorced on May 12, 1995; b)             the Corollary Relief portion of the Divorce Decree (the "Corollary Relief") stipulates that the Appellant's former spouse retains sole custody of the two minor children of the marriage; c)              the Corollary Relief also stipulates that the Appellant is required to pay support to his former spouse in respect to the children. [6]            At the hearing, the Appellant admitted subparagraphs a) and c) and denied subparagraph b) of paragraph 15 of the Reply to the Notice of Appeal. [7]            At the hearing, the Appellant had the onus of establishing, on a balance of probabilities, that the Minister's reassessment of March 25, 1999 was ill-founded in fact and in law. [8]            The "Convention sur mesures accessoires et autres réclamations" signed on May 8, 1995 by the Appellant and his former spouse provides in part as follows: GARDE ET DROITS D'ACCÈS 2.-             La demanderesse aura la garde des enfants mineurs des parties: Grégory âgé de 12 et Thomas âgé de 10 ans; 3.-             De son côté, le défendeur aura des droits d'accès suivant entente à l'amiable entre les parties sur préavis raisonnable; PENSION ALIMENTAIRE 4.-             Le défendeur versera à la demanderesse pour ses deux (2) enfants mineurs une pension alimentaire de 50,00 $ par semaine payable d'avance le premier de chaque mois (soit 200,00 $ les mois de quatre (4) semaines ou 250,00 $ les mois de cinq (5) semaines) par une série de chèques postdatés couvrant une période d'une (1) année; cette pension alimentaire sera payable dès la signature de la présente convention; [...] [9]            The divorce decree was dated May 12, 1995 giving force to the "Convention sur mesures accessoires et autres réclamations" signed on May 8, 1995. [10]          Counsel for the Minister relied on subsections 56.1(4) and 118(5) and paragraph 118(1)(b) of the Income Tax Act as amended for 1996 and 1997. [11]          Taking into consideration all of the circumstances of this appeal, including the testimony of the Appellant, the admissions and documentary evidence, the Court is satisfied that the Appellant has not succeeded in his onus. [12]          Accordingly, the appeal is dismissed. ...

Subparagraph 110(1)(f)(i) permits an offsetting deduction for the amount of a pension benefit included in income that is exempt from income tax in Canada because of a provision in a tax convention between Canada and another country ...   [3]                There is a tax convention between Canada and the Federal Republic of Germany. ... Therefore, by virtue of paragraph 3(c) of article 18 of the Canada-Germany Convention, Mr. ...

Moreover the Canada-Finland Income Tax Convention Act, 1959, section 3 reads as follows: In the event of any inconsistency between the provisions of this Act, or the Convention, and the operation of any other law, the provisions of this Act and the convention prevail to the extent of the inconsistency. ... The source is in Canada and the interest paid is not exempt by the convention. ... CR 578; [1947] CTC 343; and to Articles XIIIE and XVI of the Canada-US Tax Convention. ...

In argument, counsel for the appellant submitted first that tax conventions are to be liberally interpreted in the interest of the comity of nations. ... Where a tax convention is involved, however, the situation is different and a liberal interpretation is usual, in the interests of the comity of nations. ... This fact is indicated in the preamble to the Convention. Accordingly, it is undesirable to look beyond the four corners of the Convention and Protocol when seeking to ascertain the exact meaning of a particular phrase or word therein. ...

Income Tax Convention since both appellants received amounts from American pension plans. ... Income Tax Convention and Schedule IT to the Income Tax Regulations, as amended and applicable to the 1991 and 1992 taxation years. ... Income Tax Convention are very clear on this question. Article XVIII of the Convention reads as follows: Article X VIII- Pensions and Annuities 1. ...

If I were just a farmer I would be able to claim up to two conventions, whether I belonged to the organization or not that had something to do with my business, and I believe the interpretation is that that is my judgment. ... Dealing with the $50 convention expense, he put forward that he had attended as a farmer, not as a teacher, since in his view there was a relevance. ... On the points at issue, at the hearing the appellant did recognize the obvious weakness in this appeal with regard to the $50 convention expense in 1974, and the Board has no evidence to support its allow- ance. ...