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., res. 217 A (III), December 10, 1978, also provides at article 25 that: “(1) Everyone has the right to. .. security in the event of unemployment...”. [59] [93]   However, Canada did not ratify the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, [60] UN, G.A. res. 45/158, December 18, 1990, which provided a similar, but more specific, right to migrant workers by giving them equality of treatment with nationals of the State of employment in respect of unemployment benefits at article 54. ...

an order declaring that the Deputy Minister’s decision is discriminatory and contrary to the United Nations Convention on the Rights of Persons with Disabilities; 5.   ...

The Appellant withheld and remitted to the Receiver General for Canada withholding tax at the rate of 10% from the guarantee fees paid to [GECUS] in respect of the 1996 to 2000 taxation years, pursuant to paragraph 212(1)(b) and subsection 214(15) of the Act and Article XI of the Canada‑United States Income Tax Convention.   ... The Queen. [226] In that case, he recognized that the arm’s length principle enunciated in the OECD Guidelines inform us as to the proper interpretation and application of former subsection 69(2), as follows:   59     Subsection 69(2) of the Act is analogous to Article 9(1) of the OECD Model Double Taxation Convention on Income and Capital. ...

Chan that the proposed disposition of the shares by the PT would escape taxation in Canada because of the application of Article XIII(5)(a) of the Convention Between Canada and the United States of America with Respect to Taxes on Income and on Capital, September 26, 1980, Can. ...

T-777-23 concerns a different group whose information is being sought in relation to an Australian Tax Office request, pursuant to the Convention on Mutual Administrative Assistance in Tax Matters, 25 January 1988 (as amended on 27 May 2010), ETS 1988 No 127 (entered into force 1 June 2011, accession by Canada 21 November 2013). ...

-G. for Ontario (Labour Conventions Case) 96. Chief Justice Duff commented upon the carefully guarded language of Lord Watson and reviewed the Board of Commerce Case, supra, and Toronto Electric Commissioners v. ...

The Respondents assert that they are US residents and take the position that, if the Minister wishes to obtain information from them for the purposes of administering and enforcing the Act, then she must follow the procedure set out in Article XXVII of the Canada-United States Convention with Respect to Taxes on Income and on Capital, 26 September 1980 (entered into force 16 August 1984) as amended [the US Treaty]. ...

This hinges on the application of the Convention between the United States of America and Canada with respect to Taxes on Income and Capital (the Canada-U.S. ... Expert Evidence   [30]          The Appellant called three expert witnesses: Brian Arnold, David Rosenbloom and Richard Vann:  all three were eminently qualified to comment upon the interpretation of “permanent establishment” as used in the OECD Model Convention, the UN Model Convention and corresponding commentaries. ... In view of this fact, it did not seem advisable to insert a provision along these lines in the Model Convention. ...

The Convention, Article 3, section 2;        Income Tax Convention Interpretation Act, section 3;        The Tax Court of Canada's decision in Prévost, paragraphs 95 and 100, and paragraphs 14 and 15 from the Federal Court of Appeal's decision upholding Prévost: 3.    ... Article 12 of the Convention addresses royalties as follows:   1.         ... R., supra, the model conventions provide a guide to the interpretation and application of existing conventions. ...

The cost of attending the annual convention would be deductible pursuant to subsection 20(10) of the Income Tax Act [3]. Although counsel for the Respondent had raised in argument the issue of whether both Appellants had attended the convention since only Elaine Armstrong-McLean had discussed the convention during her testimony, I find on a balance of probabilities that both attended the convention. It seems clear that both Appellants were involved and active in the partnership and therefore more likely than not that both attended the convention. ...