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Upon receipt of the Board’s report, the Minister may take further steps regarding the permit if she considers it advisable to do so (subsection 129(3)). [48]            In October 2001, the International Maritime Organization adopted the International Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001 (the “ Convention ”). ... (i)             The Convention [103]        With respect to the Convention, the Society notes that Article 4(1) requires the parties thereto to prohibit and/or restrict, in accordance with the requirements specified in Annex 1, the application, re-application, installation, or use of harmful anti-fouling systems on ships referred to in article 3. ... This is essentially the same language contained in Annex 1 to the Convention. ...

This arrangement was put in place by the Appellant and his employer to conform to their understanding of the requirements of the US and Canadian tax laws and the Canada-US Tax Convention. ...

However, nothing turns on this as the Tax Court Judge acknowledged that the appellant was a dual resident and proceeded to render judgment on that basis. [5]                The appellant's second argument is that the Judge incorrectly applied the first tie-breaker rule (centre of vital interests) in the Canada-Egypt Income Tax Convention Act, 1984, being Part IV of S.C. 1984, c. 35. [6]                The appellant submits that the Judge took into account economic considerations, but failed to take into account personal considerations. ...

Tax Convention (the Treaty) to an amount paid to him by Jets Hockey Ventures, a partnership which owned and operated the Winnipeg Jets Hockey Club at that time. ... Income Tax Convention (the " Canada – USSR Treaty ") applies to residents of Belarus. 3. ... Canada: [3] Contrary to an ordinary taxing statute a tax treaty or convention must be given a liberal interpretation with a view to implementing the true intentions of the parties. ...

Income Tax Convention (1980). This had the effect of limiting the tax for those years to 15% of the Wage Loss Replacement Plan benefits, or $4,480.50, $4,581.30 and $3,496.05. [12]     Counsel for the respondent in her written submissions states that the issue is whether the CPP payments are caught by paragraph 6(1)(f) of the Income Tax Act so that they are considered to be income from an office or employment. ... Income Tax Convention, (1980), Article XVIII reads in part as follows 1.    ... For the purposes of this Convention, the term "pensions" includes any payment under a superannuation, pension or retirement plan, Armed Forces retirement pay, war veterans pensions and allowances and amounts paid under a sickness, accident or disability plan, but does not include payments under an income-averaging annuity contract or any benefit referred to in paragraph 5. 4.    ...

Person in need of protection 97 (1) A person in need of protection is a person in Canada whose removal to their country or countries of nationality or, if they do not have a country of nationality, their country of former habitual residence, would subject them personally (a) to a danger, believed on substantial grounds to exist, of torture within the meaning of Article 1 of the Convention Against Torture; or (b) to a risk to their life or to a risk of cruel and unusual treatment or punishment if (i) the person is unable or, because of that risk, unwilling to avail themself of the protection of that country, (ii) the risk would be faced by the person in every part of that country and is not faced generally by other individuals in or from that country, (iii) the risk is not inherent or incidental to lawful sanctions, unless imposed in disregard of accepted international standards, and (iv) the risk is not caused by the inability of that country to provide adequate health or medical care. ... Application for protection 112 (3) Refugee protection may not be conferred on an applicant who (a) is determined to be inadmissible on grounds of security, violating human or international rights or organized criminality; (b) is determined to be inadmissible on grounds of serious criminality with respect to a conviction in Canada of an offence under an Act of Parliament punishable by a maximum term of imprisonment of at least 10 years or with respect to a conviction outside Canada for an offence that, if committed in Canada, would constitute an offence under an Act of Parliament punishable by a maximum term of imprisonment of at least 10 years; (c) made a claim to refugee protection that was rejected on the basis of section F of Article 1 of the Refugee Convention; or (d) is named in a certificate referred to in subsection 77(1).   Demande de protection 112 (3) L’asile ne peut être conféré au demandeur dans les cas suivants: a) il est interdit de territoire pour raison de sécurité ou pour atteinte aux droits humains ou internationaux ou criminalité organisée; b) il est interdit de territoire pour grande criminalité pour déclaration de culpabilité au Canada pour une infraction à une loi fédérale punissable d’un emprisonnement maximal d’au moins dix ans ou pour toute déclaration de culpabilité à l’extérieur du Canada pour une infraction qui, commise au Canada, constituerait une infraction à une loi fédérale punissable d’un emprisonnement maximal d’au moins dix ans; c) il a été débouté de sa demande d’asile au titre de la section F de l’article premier de la Convention sur les réfugiés; d) il est nommé au certificat visé au paragraphe 77(1).   ...

Overview [1]   The Appellant, a resident of Luxembourg, claimed an exemption from Canadian income tax under Article 13(5) of the Canada-Luxembourg Income Tax Convention 1999 (the “Treaty”) in respect of a large capital gain arising from the sale of shares (the “Shares”) of Alta Energy Partners Ltd. ... The preamble of the Treaty states that the two governments desired “to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.” ... The rule, if adopted, could be included in the  Income Tax Conventions Interpretation Act  so that it would apply in respect of all of Canada’s tax treaties. ...

Any gain or profit realized therefrom was taxable in the jurisdiction where the property was located and Articles VI and XII 1(1) of the Tax Convention applied. ... This letter purported to inform the recipient that the defendant was not a Swiss corporation, that it was unknown to the Swiss authorities and that it was nota Swiss resident under the double taxing provisions of the Canada-Switzerland Tax Convention. ... On that basis, therefore, the defendant fell within the definition of residence" in Article IV.1 of the Tax Convention and could avail itself of the limitations set out in Article VI 1.1 of the Convention. ...

The officer’s decision also violates sections 7 and 12 of the Canadian Charter of Rights and Freedoms, Part I of the Constitution Act, 1982, being Schedule B to the Canada Act 1982 (UK), 1982, c 11 [Charter] and Article 3 of the 1984 United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. [3]   No intervention is warranted in this case. [4]   PRRA applications involve questions of mixed fact and law, so the standard of review applicable to them is reasonableness (Flores Carillo v Canada (Minister of Citizenship and Immigration), 2008 FCA 94 at para 36; Huang v Canada (Citizenship and Immigration), 2018 FC 940 at para 10). ...

The Minister applied a provision in the Canada-United States Income Tax Convention which deems an enterprise of one state to have a permanent establishment in the other state in specified circumstances. ...