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Income Tax Act 81(1) There shall not be included in computing the income of a taxpayer for a taxation year, (a) an amount that is declared to be exempt from income tax by any other enactment of the Parliament of Canada, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada; Loi sur les Indiens 87(1) Nonobstant toute autre loi fédérale ou provinciale, mais sous réserve de l’article 83, les biens suivants sont exemptés de taxation: a) le droit d’un Indien ou d’une bande sur une réserve ou des terres cédées; b) les biens meubles d’un Indien ou d’une bande situés sur une réserve. (2) Nul Indien ou bande n’est assujetti à une taxation concernant la propriété, l’occupation, la possession ou l’usage d’un bien mentionné aux alinéas (1)a) ou b) ni autrement soumis à une taxation quant à l’un de ces biens. 90(1) Pour l’application des articles 87 et 89, les biens meubles qui ont été: b) soit donnés aux Indiens ou à une bande en vertu d’un traité ou accord entre une bande et Sa Majesté, sont toujours réputés situés sur une réserve. Loi de l’impôt sur le revenu 81(1) Ne sont pas inclus dans le calcul du revenu d’un contribuable pour une année d’imposition: a) une somme exonérée de l’impôt sur le revenu par toute autre loi fédérale, autre qu’un montant reçu ou à recevoir par un particulier qui est exonéré en vertu d’une disposition d’une convention ou d’un accord fiscal conclu avec un autre pays et qui a force de loi au Canada; The Crown contends that section 87 has no application in this case because no reserve has been set aside for the Fort Good Hope Band. ...

As official interpreters, Courts have the power to fix the “intended” or legally correct meaning of words, but they cannot fix the conventions and practices on which the ordinary meaning depends. ... In this limited sense, the meaning derived from linguistic conventions is objective and capable of functioning as a constraint in statutory interpretation. 10. ...

Angle worked with Transworld Exploration Ltd. from the inception of the Company until today in a capacity of assisting the Company with handling all personal engagements, private telephone conversations, running said corporation when I was out of the city on numerous occasions, handling all entertainment, making all mining conventions and other conventions that were suitable for the Company at the time and helping to promote the Company’s stock holdings through her contacts since Mrs. ...

Gagnon redigérent un acte intitulé: CONVENTION DE SOCIÉTÉ, ici produit sous la cote A-l, comme pièce annexe du Mémorandum. ... Sans méconnaitre que le vocable de ‘‘société’’, selon l’acception du droit civil, suffirait à atteindre, le cas échéant, certaines associations, mais de nature lucrative, celles-là, je n’ai relevé qu’un seul passage digne de remarque, le second principe énoncé par l’article 1831: “Toute convention par laquelle l’un des associés est exclu de la participation dans les profits est nulle.” ...

This is how the issue and the method to resolve it are described: [7] The term “ fixed base regularly available to him ” is not defined in the Convention or in the Income Tax Act. ... Paragraph 1 gives a general definition of the term “permanent establishment” which brings out its essential characteristics of a permanent establishment in the sense of the Convention, i.e. a distinct “situs”, a “fixed place of business”. ... As stated in the OECD Model Convention commentary, to be “fixed”, a business “must be established at a distinct place with a certain degree of permanence”. ...

It is useful in this respect to refer to section 4.1 of the Income Tax Conventions Interpretation Act which specifically provides for this result. ...   [375] The relevant commentary relates to Article I of the model convention. ... Income Tax Conventions Interpretation Act   4.1 Notwithstanding the provisions of a convention or the Act giving the convention the force of law in Canada, it is hereby declared that the law of Canada is that section 245 of the Income Tax Act applies to any benefit provided under the convention.   ...

This is not to say that there may not be an international convention between Canada and another country, duly implemented by statute in both countries, that would authorize such examination. I do not recall any such convention that contemplates pre-trial examination of potential witnesses as opposed to obtaining evidence in one country for use at trial in another country. Plaintiffs counsel have not been able to find in this case an international convention of the kind referred to by Jackett, CJ. ...

If the interest is to be regarded as paid within the meaning of the Income Tax Act, the appellant should, pursuant to sections 212 and 215 of the Act, have paid the respondent an amount equal to 25 per cent because of the Canada-US Convention) of the amount of interest deemed to be paid, as tax on the income from Canada of non-resident persons. ... The respondent argued that the creditor company received a security in full payment of its interest pursuant to section 76 of the Act; that the said interest is deemed to have been paid on the date when the creditor received the security, pursuant to subsection 214(4); and that the 25 per cent tax provided for in paragraph 212(l)(b) should be payable by the appellant under subsection 215(1) (reduced to 15 per cent under the Canada-US Convention). ... And as another author says, credit on the right and debit on the left: This is a convention: the credit can be put on the left and the debit on the right, so long as the practice followed is consistent. ...

Pierre and Miquelon who is the subject of a report made pursuant to paragraph 20(1)(a); or   (b) a person who has been determined to be not eligible to make a claim to be a Convention refugee by reason of paragraph 46.01(1)(b) and who is to be removed to a country with which the Minister has entered into an agreement under section 108.1 for sharing the responsibility for examining refugee claims.   ... (d) a judge of the Court shall dispose of the application without delay and in a summary way and, unless a judge of the Court directs otherwise, without personal appearance; and   (e) no appeal lies from the decision of the Court with respect to the application or with respect to an interlocutory judgment.     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. (2) A person in Canada who is a member of a class of persons prescribed by the regulations as being in need of protection is also a person in need of protection.  ...   112. (1) A person in Canada, other than a person referred to in subsection 115(1), may, in accordance with the regulations, apply to the Minister for protection if they are subject to a removal order that is in force or are named in a certificate described in subsection 77(1).                                                                     ...   113. ... Pierre and Miquelon who is the subject of a report made pursuant to paragraph 20(1)(a); or   (b) a person who has been determined to be not eligible to make a claim to be a Convention refugee by reason of paragraph 46.01(1)(b) and who is to be removed to a country with which the Minister has entered into an agreement under section 108.1 for sharing the responsibility for examining refugee claims.   70 ...

(i)                   An unreasonable $423 convention registration fee expense. ... In subparagraph 17(ccc)(i) the expense referred to is for participation in the biennial convention of the Fédération québécoise des sociétés de généalogie at which the appellant had a booth in the exhibitors’ hall and which was attended by many of his clients.   56.               ... (d)   The following additional expenses for the use of a vehicle should be allowed:        2001: $2,088        2002: $1,733 (e)   The $50 expense incurred in 2001 to sponsor a golf tournament and the $425 convention fee claimed for 2002 must be allowed. ...