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The argument was that the requirement under the Income Tax Act that women such as the appellants must include in income such maintenance payments received for the support of their children discriminates against women in contravention of the Declaration on the Elimination of Discrimination against Women, the Convention on the Elimination of All Forms of Discrimination against Women and the United Nations Declaration of the Rights of the Child. ... In the circumstances it is not necessary for me to deal with the other arguments advanced by the appellants beyond observing that conventions and declarations of the type relied upon by the appellants here, even though signed by Canada, do not, unless implemented by statute, have the force of law in Canada so as to override domestic legislation, although they may be useful guides to interpretation. ...

Nassau Jet Holiday, the programme our men have been developing for you for nearly a year, will be the finest business convention we’ve ever held. ... Indeed in the Hale case (supra) no attempt appears to have been made to tax any supposed benefit in respect of his own. attendance at the convention. ... Counsel went on to emphasize the business aspects of the trip itself and its program, and to characterize the whole trip as a business convention. ...

Neufeld and the Midway Dental Clinic throughout her 1982 taxation year, and that the amounts claimed by her for convention and seminar expenses were not deductible from her employment income. ... Little information was provided at the hearing regarding the "convention" and the "seminar" but there was no substantial indication from the Minister that the attendance was not in a direct sense related to her work as a dental hygienist. I am satisfied that neither the convention expenses nor the seminar expenses would be clearly deductible items for Miss Bradford in her capacity as an "employee". ...

In my view, the Trial judge was right in holding that such a contract is “lease of motion picture films” within the meaning of paragraph IV of article 13 of the Canada-France Income Tax Convention (1951 SC c 40). ...

Canada, 2007 FC 323             Date: 20070326   Docket: IMM-3257-06 Citation: 2007 FC 323 [ENGLISH TRANSLATION] Montréal, Quebec, March 26, 2007 PRESENT: The Honourable Madam Justice Tremblay-Lamer    BETWEEN: MYRNA RIVAS Applicant and   THE MINISTER OF CITIZENSHIP AND IMMIGRATION   Respondent       REASONS FOR JUDGMENT AND JUDGMENT   [1]                This is an application for judicial review of a decision by the Refugee Protection Division (RPD) of the Immigration and Refugee Board whereby the applicant is not a Convention refugee or a person in need of protection, as defined in sections 96 and 97 of the Immigration and Refugee Protection Act, S.C. 2001, c. 27 (the Act) ...

En juillet 1978, tout comme les quelque 500 autres agents, il a reçu de son employeur un montant forfaitaire de $2,500 suite à une lettre d'entente concernant le remboursement des repas des agents, laquelle lettre fait partie de la Convention collective de travail 77-81 entre le gouvernement du Québec et le Syndicat des agents de la paix de la fonction publique. ... Avant la convention de 1978 ils étaient remboursés par l'employeur s'ils se trouvaient à dix milles ou plus en dehors de la ville à l'heure d’un repas au taux de $2.75 pour un goûter sur le pouce; $4.75 et $6.50 pour le dîner et le souper au restaurant. ... Finalement, la Convention ne prévoit pas que les agents quittant leur emploi ou prenant leur retraite après réception du $2,500 doivent retourner ce montant ou aucune portion de ce montant, à l'employeur. ...

In the Canada/France Tax Convention, Article II, subsection 3(b) states:   3.         The existing taxes to which the Convention shall apply are in particular:             (a)        …   (b)        in the case of France, the income tax, the corporation tax, the tax on wages and salaries (regulated by the provisions of the  Convention  applicable, as the case may be, to business profits or to income from independent personal services) the solidarity tax on net wealth, and any withholding tax, prepayment or advance payment with respect to the aforesaid taxes, (hereinafter referred to as “French tax”).   ...

He arrived in Canada in July 1993 as a political Convention refugee (Exhibit A-1). He claimed political refugee status on April 16, 1996, and the Convention Refugee Determination Division found him to be a Convention refugee on April 18, 1996. ...

  [6]                The Board first found there was no connection between the principal applicant’s alleged fear and one of the five Convention grounds. ...   [7]                First, the principal applicant argues that the Board erred in finding that there was no connection between the fear alleged by the principal applicant and one of the five Convention grounds. ... Assessing subjective fear may be based on the principal applicant’s behaviour, such as the delay in leaving the country of persecution or torture, the voluntary return to the country of persecution, failure to seek protection in a country that is signatory to the Convention and the delay in seeking protection in Canada. ...

In his amended reply to the notice of appeal the respondent relied, inter alia, on paragraph 212(1)(d), subsections 212(5), 214(1), 215(1), 215(3), 227(8), 227(9) and 227(10) of the Income Tax Act (SC 1970-71-72, c 63, as amended), on subsection 10(2) of the Income Tax Application Rules (ITAR), on Article Vlll(1) and (3) of the Tax Convention between Canada and the Federal Republic of Germany, and on Article XIII(3) and (4) of the Tax Convention between Canada and France applicable to the years on appeal. ... In this sense, the Convention applies. A non-resident is taxable on film rental income—because this involved income for the rental of films—and Société Nouvelle de Cinématographie had an obligation to withhold the tax, because the non-resident is taxable, but also as a result of subsection 215(3), which requires the mandatary to make withholdings in such cases....I would simply conclude by saying, despite the fact that there are many contracts in these cases, despite the fact that studying them may seem tedious and burdensome in certain respects, the fact remains that in the final analysis the position of the department has always been clear, and that in our opinion, the nonresidents were taxable, and accordingly Société Nouvelle de Cinématographie should have withheld the tax required. ...