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[FN2: <p>Schedule B, Article II(f) to<em>An Act to Amend the Canada-United States of America Tax Convention Act</em>, 1943, and the<em>Canada-United States of America Tax Convention Act</em>, 1944, SC 1950, c 27. ... See Schedule B to<em>An Act to Amend the Canada-United States of America Tax Convention Act</em>, 1943, and the<em>Canada-United States of America Tax Convention Act</em>, 1944, SC 1950, c 27, particularly Article IV. ... The Minister, before us, relied on this Convention in support of his submission that the warrants also had their situs in Canada. ...

This convention was approved and declared to have the Force of law in Canada by the Canada-United States of America Tax Convention Act, 1943. Subsequent amendments to the Convention were also approved and declared to have the force of law in Canada by statutes duly enacted by the Parliament of Canada. ... On the other hand, the Canada-US Reciprocal Tax Convention was by statute approved and declared to have the force of law in Canada. ...

Page 3 describes the calculation for the Federal foreign tax credit as follows: Line 507 Income tax on profits tax paid to a foreign country 1,014.22 508 Net foreign income 3,382.05 Basic Net income 5,310.05 x federal = 0 tax (0) [5] Article 4 of the Canada-Australia Convention provides that tax paid in Australia is deductible from tax payable in Canada. ...

On consent, however, that matter was resolved at the original hearing before me on July 30, 1999. 4        Although my order of that date reflects that resolution, paragraph 3 was erroneously included given that the initial stage of this dispute is the determination of a Charter argument by the applicant with respect to the Canada-United States Income Tax Convention, 1980. 5        Further to the hearing of October 13, 1999, counsel for the applicant suggested that at the same time that the Court was dealing with the constitutional arguments, it also entertain the administrative law arguments which he wishes to make. 6        I am of the view that they should not proceed simultaneously. ...

Justice Shore BETWEEN: BRAYAN ALEXANDER CARDENAS GIL MARIANA CARDENAS VELASCO DAISY JOHANA VELASCO OLMOS Applicants and MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent JUDGMENT AND REASONS [1]   This is an application for judicial review of a decision by the Refugee Appeal Division of the Immigration and Refugee Board of Canada [Board] dated January 16, 2019. [2]   The Board determined that the applicants are neither Convention refugees nor persons in need of protection under sections 96 and 97 of the Immigration and Refugee Protection Act, SC 2001, c 27. [3]   The Board concluded that it did not believe the allegations as described by the respondents. ...

Page 3 describes the calculation for the Federal foreign tax credit as follows: Line 507 Income tax on profits tax paid to a foreign country 1,014.22 508 Net foreign income 3,382.05 Net income 5,310.05 x Basic federal = 0 tax (0) Article 4 of the Canada-Australia Convention provides that tax paid in Australia is deductible from tax payable in Canada. ...

The President is the only full-time elected position.   27        Under the Constitution, the Union is governed by an annual Convention, but between Conventions the business is conducted by the Council which is comprised of 28 members. ... The Constitution provides that the Council, between Conventions, is the governing body of the Union. ... The governing body of the Union is the Council when it is not in Convention. ...

Both counsel agreed that the Canada-US Tax Convention Act, SC 1943-44, 7 & 8 Geo VI, c 21, really need not be considered in the case at bar for the Convention only applies if the plaintiff was in fact carrying on business in Canada or if it had industrial or commercial profits derived from Canadian sources. ...

.; h) during the Relevant Years, the Appellant worked full time as an employee, 5 to 7 days per week at 8 to 16 hours per day; i) the Appellant spent 8 to 12 hours per week on the Amway Activity; j) the Appellant did not spend sufficient time on the Amway Activity to make it profitable; k) the Appellant did not provide a business plan to determine if the Amway Activity would be profitable; l) the expenses of the Amway Activity increased over the course of the Relevant Years; m) during the Relevant Years, expenses substantially exceeded gross revenues from the Amway Activity; n) the Appellant does not plan any material changes to the Amway Activity in the near future; o) the Appellant has discontinued the operation of the Amway Activity; p) the Appellant is a carpenter and did not have experience in marketing and sales; q) the Amway Activity sales included purchases by the Appellant and his family for personal use; r) the Amway Activity was not a purely commercial venture; s) expenses claimed by the Appellant included expenses in respect of the Appellant's travel to conventions in excess of two conventions per year; t) the Appellant claimed expenses relating to his family's vacations, which he combined with trips made in respect of the Amway Activity; u) the Amway Activity is undercapitalized; v) the Appellant did not have a reasonable expectation of profit from the Amway Activity during the Relevant Years; w) the expenses claimed in relation to the Amway Activity personal or living expenses of the Appellant; and x) the expenses claimed in relation to the Amway Activity were not reasonable in the circumstances. [3] Assumptions 7(b) to (h) inclusive, (k) to (q) inclusive, (s), (t) and (w) were either confirmed or were not refuted by the evidence. [4] The Appellant has his high school. ...

Decision under Review [3]   In its June 5, 2018 decision, the RPD determined the Applicants were not Convention refugees or persons in need of protection. ... The RPD therefore did not assign any weight to the supporting statements that she provided as they were of no probative value to the assessment of her credibility. [9]   The Applicants claimed refugee status as part of a particular social group as Convention refugees, i.e. adults protecting minor-age children from an adult pedophile. ...