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The relevant portions of the 1942 Tax Convention are as follows: Article I. ... Paragraph 3 of Article VII of the Convention is not intended to have any implications for interpretation of the 1942 Convention, but is intended to assure that under the Convention deductions are allowed by a Contracting State which are generally allowable by that State. ... The 1942 Convention used the term “industrial and commercial profits” while the 1980 Convention referred to "business profits.” ...

Milfort‑Laguere is not a Convention refugee nor a person in need of protection. ... Milfort-Laguere’s failure to regularize her status in Brazil in relation to the issue of exclusion by operation of Article 1E of the Convention? ... Analysis and decision [24]   The case law has developed a framework to determine whether a person meets the criteria of Article 1E of the Convention. ...

They allege that they risk being persecuted in Colombia and that they are also persons in need of protection because of their involvement in a non-governmental organization [NGO]. [3]   The Convention ground invoked by the applicants before the Refugee Protection Division [RPD] was their membership in a social group: [TRANSLATION]  “social workers seeking to defend human rights, members of an NGO that works with displaced persons in order to help them reclaim their lands” (Certified Tribunal Record [CTR] at p 371). [4]   The RPD found that the applicants did not establish a reasonable possibility of persecution based on a Convention ground or that, on a balance of probabilities, they were personally subjected to a danger of torture, to a risk to their lives or to a risk of cruel and unusual treatment or punishment if they were to return to Colombia. ... The RAD affirmed the decision rendered by the RPD, finding that the applicants were neither Convention refugees nor persons in need of protection within the meaning of sections 96 and 97 of the IRPA. [7]   For the reasons that follow, the application for judicial review is dismissed. ... Reasonableness of the decision [79]   Regarding the merits, the applicants are contesting the RPD’s findings, upheld by the RAD, that the two incidents which occurred prior to their departure from Colombia (the call on September 30, 2016, and the robbery on October 27, 2016) have no nexus to a Convention ground and do not establish a personalized risk. ...

Counsel for the respondent also argued that, in any event, the appeal was bound to fail for two additional reasons: first, because the notice of reassessment sent to the respondent by the Minister of National Revenue was vitiated by an irregularity, and, second, because the payment made to the trustees of the AMCA plan was the payment of a “pension” within the meaning of the Canada-US Tax Convention. The argument founded on the Canada-US Tax Convention was made in the Trial Division. ... The Protocol of the Convention specifies that the word “pension” in the Convention means “periodic payments made in consideration for services rendered or by way of compensation for injuries received.” ...

., significant discrepancies were noted between the amounts paid by the R.A.M.Q. and the professional income reported by the appellant, namely $22,189 in 1992, $27,543 in 1993 and $47,189 in 1994; (g) Since the appellant could not explain the discrepancies, the amounts referred to in subparagraph 7(g) were added to his income for the years at issue; (h) Amounts totalling $41,752 (1992), $36,172 (1993) and $26,795 (1994) were disallowed by the Minister as expenses for a variety of reasons, as set out below: 1992 1993 1994 Total Disallowed expenses Dues and donations $2,898 $2,450 $700 $6,048 Insurance $4,971 $4,836 $4,636 $14,443 Salaries and benefits $5,690 $1,398 $5,353 $12,441 Professional fees $3,799 $3,162 $1,561 $8,522 Automobile expenses $1,377 $1,926 $1,677 $4,980 Conventions and training $17,229    $18,942    $10,111 $46,282 Home office expenses $2,049 $2,110 $2,007 $6,166 Interest (carrying charges) $3,739 $1,348 $750 $5,837 TOTAL DISALLOWED EXPENSES    $41,752    $36,172    $26,795 $104,719 expenses claimed as professional fees were disallowed because they were personal expenses (e.g. funeral costs for the appellant's father, painting or music classes) and several amounts could not be justified by documents; expenses claimed as donations and dues were disallowed, including a loan to the Club de golf de Baie-Comeau and the appellant's professional dues for membership in the Federation of General Practitioners of Quebec, which were paid by the R.A.M.Q. and which the appellant had already claimed; payments of life insurance premiums were disallowed because they were personal expenses; under "salaries", the appellant had included the employee's portion of contributions to the Quebec Pension Plan, of unemployment insurance premiums, and of premiums for the Régime de l'assurance-maladie du Québec and taxes, and those amounts were disallowed; expenses claimed under "conventions and training" were disallowed because of a lack of vouchers or because they involved personal travel by or personal expenses of the appellant; the appellant had also claimed the non-eligible 20% of restaurant or entertainment expenses; amounts claimed for the use of the appellant's home were disallowed because his principal place of business was at the Médicentre Boréal; certain expenses for the use of an automobile were disallowed because the vouchers showed expenses for two different vehicles; amounts claimed for interest on a credit line were disallowed because they were inconsistent with his personal expenses; (i) Amounts of $25,020 (1992), $29,202 (1993) and $24,973 (1994) that the appellant had reported as rental losses on immovable property in St-Augustin-de-Desmaures were disallowed by the Minister because there was no reasonable expectation that a profit would be made from renting that single-family home during the years at issue; (j) Since purchasing that home in 1990, the appellant has claimed $127,819 in losses over a period of five years; (k) The annual rent collected for the house does not cover the mortgage interest; (l) The appellant indicated that he could not increase the rent because he would then not have been able to rent the house, which shows that the property was generating all the income it could; (m) Since the appellant has been preparing his own financial statements since the early 1980s, he ought to have known that, given their nature, he could not claim the expenses disallowed by the Minister for the years at issue; (n) The R.A.M.Q. reports were very clear and made it possible for the appellant to report his professional income appropriately during the years at issue; (o) Since the appellant knowingly, or under circumstances amounting to gross negligence, made false statements in his income tax returns for the 1992, 1993 and 1994 taxation years by not reporting all his income and by claiming non-deductible expenses for each of the years at issue (see table), penalties of $6,589, $5,083 and $6,831, respectively, were assessed under subsection 163(2) of the Income Tax Act: 1992 1993    1994 Expenses Professional fees $949 $3,162 $1,561 Dues and donations $1,668 $2,450 $700 Conventions and training $17,229 $18,942 $10,111 Total $19,846 $24,554 $12,372 Income R.A.M.Q. $29,047 $15,913 $39,114 Amount subject to penalty $48,893 $40,467 $51,486 [6] With regard to the assessment of penalties, counsel for the respondent drew a distinction between the income from the R.A.M.Q. that Mr. ... The most substantial item among the disallowed expenses that gave rise to penalties is conventions and training expenses, which total $46,282 for the three years. [8] In addition to being substantial, those expenses are totally bizarre: obviously, they could not be considered legitimate in computing professional income. ...

B)         In the alternative, that the Requirement as worded is unreasonable and constitutes a far-reaching fishing expedition and totally bypasses the procedures laid out in the Tax Convention between Canada and the Grand Duchy of Luxembourg. [3]                 The applicant was incorporated in Luxembourg in 1998 and, for tax purposes, is a resident of Luxembourg. ... By letters dated September 17, 1998, CCRA granted waivers with respect to both these regulations (waiver from withholding tax). [12]            The applicant submits that the Canada-Grand Duchy of Luxembourg Tax Convention provides for the exchange of information between the competent authorities of both contracting states as is necessary for the carrying out of the provisions of the Convention, to underline that at no time did the officials of the CCRA communicate with the Luxembourg tax authorities with respect to any matter pertaining to the applicant's activities. [13]            The issue in dispute is whether or not the applicant is bound to disclose income earned in Canada if they were considered to have a "permanent establishment" in accordance with Article V of the Tax Convention between Canada and the Grand Duchy of Luxembourg. ...

Upon arrival in Ethiopia, he applied for a permanent resident visa in Canada as either a member of the Convention refugee abroad class or as a member of the humanitarian-protected person abroad designated class.   ... In due course, the Applicant fled Eritrea, evading national service, and entered Ethiopia where he is living presently. [7]   The Applicant submitted an application in 2017 for a permanent resident visa in Canada as a member of the Convention refugee abroad class or as a member of the humanitarian-protected persons abroad designated class.   ... The Officer determined that the Applicant was neither a member of the Convention refugee abroad class nor the humanitarian-protected persons abroad designated class.   ...

Dans le but de faciliter la perception et la remise de l’impôt établi par la présente loi, ou de prévenir le double paiement de cet impôt sur le même tabac, le ministre peut faire avec un vendeur telles conventions qu’il jugera à propos et telles conventions seront sujettes à la présente loi. ... Le mandat est gratuit s’il n’y a une convention ou un usage reconnu au contraire. ... Elle est une conséquence de la liberté de tester, et nous pouvons admettre la même solution dans le cas du mandat, comme étant la conséquence de la liberté des conventions, et cela sans que le contrat cesse d'être un contrat de mandat. ...

Appellants’ counsel drew the Court’s attention to the Canada-United States Income Convention Act, 1984, Chapter 20, S.C. 1984, subsection 3(2) which reads: (2) In the event of any inconsistency between the provisions of this Act, or the Convention, and the provisions of any other law, the provisions of this Act and the Convention shall prevail to the extent of the inconsistency. ... Article IV, paragraphs 1 and 2, of the Canada-United States Income Tax Convention (1980) reads: 1. ... Due to these factors, it is useful to review the tests applicable under the Canada-United States Income Tax Convention (1980), Article IV, subparagraph 2(a). ...

MTGL is a shareholder of MenuPalace. [4] He stated that because he was a thirty-three per cent shareholder of Dealfind and he contributed to its growth, he should get thirty per cent of the expenses. [5]              According to the appellant, he went to Las Vegas to attend the Yellow Pages Convention ("Convention"). ... However, in response to subsequent questions by counsel for the respondent, the appellant admitted that the Convention had ended on April 19, 2011, which was the day before he arrived. ... He subsequently admitted, however, that he had arrived in Las Vegas the day after the Convention ended and immediately before the Easter long weekend. ...