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Tax Convention provides: Notwithstanding the provisions of Articles III and IV, profits which a resident of one of the territories derives from operating ships or aircraft shall be exempt from tax in the other territory. ... That neither Section 10(1) (c) of the Income Tax Act nor Article V of the Tax Convention exempts earnings of the appellant from managing or agency or stevedoring services which it renders in Canada to other corporations: 2. ... Tax Convention, I do not rely upon the translation of the Convention, which appears as a Schedule to the French text of the Statutes of Canada 1946, c. 38. ...

Trip No. 14 – OshKosh- This flight was for attendance at the OshKosh convention. There was no evidence given that the convention had anything to do with the Socata distributorship agreement. This trip was personal in nature as was the similar OshKosh convention the previous year ...

SSee Model Double Taxation Convention on Income and on Capital, Report of the OECD Committee on Fiscal Affairs, 1977, Organisation for Economic Co-operation and Development, Paris. ... Draft or Model Convention has never specifically dealt with that category of services, sub- paragraph 212(1)(d)(iii) cannot be interpreted in light of the O.E.C.D. ... Klaus Vogel, “Klaus Vogel on Double Taxation Conventions, A Commentary to the OECD-, UN- and US Model Conventions for the Avoidance of Double Taxation on Income and Capital With Particular Reference to German Treaty Practice", Third Edition, Kluwer Law International, London — The Hague — Boston. 3 Further support for this proposition can be found in the dicta of Thurlow C.J. in R. v. ...

In support of this position, he referred to the fact that, by Sections 106 and 108 (which it may be noted are in Part 3 of the Income Tax Act, rather than Part 1), income tax is imposed in Canada on interest payable to nonresidents on the gross amount of such interest as income, and to the several provisions of the Convention and Protocol between Canada and the United States for the Avoidance of Double Taxation, as well as the provisions of The Canada-United States of America Tax Convention Act 1943, Statutes of Canada 1943- 1944, c. 20 (as amended by Statutes of Canada 1950, ce. 27), by which the Convention and Protocol were ratified and declared to have the force of law in Canada, and particularly to Section 3 of that Act, by which it is provided that, in a case of inconsistency between the Convention and Protocol and any other law, the provisions of the Convention and Protocol shall prevail. In my opinion, despite the claim that the reassessments result in double taxation of the interest in question, and despite the purpose of the Convention, as declared in it, of avoiding double taxation, the Convention goes no further in avoiding double taxation than what is set out in its several Articles, none of which, in my opinion, affords in the present situation relief to any greater extent than what is to be found in the provisions of The Income Tax Act. Article XV of the Convention as amended, effective January 1, 1949, provides that "1. ...

  [7]                The 25% rate of tax specified in subsection 212(1) of the Income Tax Act may be reduced by an international income tax convention. During the period relevant to this appeal, the rate of tax on interest paid to a resident of Belgium was reduced to 15% by virtue of the Canada-Belgium Income Tax Convention (1976), enacted as a law of Canada by An Act to implement conventions for the avoidance of double taxation with respect to income tax between Canada and France, Canada and Belgium and Canada and Israel, S.C. 1974-75-76, c. 104. (The 1976 convention was replaced effective 2004, see S.C. 2002, c. 24 ...

The company claimed a refund of this latter amount from Nova Scotia on the theory that the provisions of the Canada-United States of America Tax Convention Act, 1944-45 (Can.), c. 31, was applicable. ... Act, but in the present case, no such question arises for the convention by its terms deals only with ‘the tax imposed under the Dominion Suc- cession Duty Act 9. ... The convention does not purport to affect any provincial power.’’ But with due deference, I cannot agree with the Court below on the second point. ...

International Copyright and Neighbouring Rights:  The Berne Convention and Beyond, vol.  ... WIPO Intellectual Property Handbook:  Policy, Law and Use, chapter 5, “International Treaties and Conventions on Intellectual Property”, No. 489, 2nd ed.  ... Ginsburg, International Copyright and Neighbouring Rights: The Berne Convention and Beyond (2nd ed. 2006), vol. ...

Indeed, the Tax Court Judge, while observing that the appellant purchased eighty percent of his household goods wholesale from Amway and took a few trips to conventions at Niagara Falls and Atlanta, did not base his decision on personal benefit. ...

Respondent     REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Calgary, Alberta, on June 13, 2007) PELLETIER J.A. [1]                In order to succeed in this appeal, the appellant Her Majesty the Queen must persuade us that one transaction in the series of transactions in issue is an avoidance transaction, and that the tax benefit achieved by the respondent MIL (Investments) S.A. is an abuse or misuse of the object and purpose of article 13(4) of the Convention between Canada and the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of fiscal Evasion with respect to Taxes on Income and on Capital (the Tax Treaty) ...

  [1]               The issue in this appeal is whether the Appellant is entitled to claim deductions of $22,760.38 pursuant to the Foreign Convention and Tour Incentive Program (“FCTIP”). ...