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It provides: 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 ina tax convention or agreement with another country that has the force of law in Canada. ...

With respect to Mr Babcock it was reported in the minutes of the meeting as shown in Exhibit R-2 that he did speak at the convention and reported on a meeting held in Halifax. ...

With respect to the first of those the Appellant takes the position of artists’ and scriptwriters’ fees are costs of production and that they must be paid to make the copies and that particularly with respect to the scriptwriters’ fees they are protected under copyright provisions in Section 3 of Article 11 of the Canada — UK Tax Convention. ...

As Mr Charles Marchand in fact died in late August 1974, only seven-twelfths of the $26,250 was included in income. 4.19 In computing its income for the years 1972 and 1973, Economy Ware Kitchen Specialties Ltd claimed, inter alia, all the expenses listed below along with all the necessary supporting documents: 1972 1973 Travel expenses $ 9,095 $ 5,253 Advertising and promotion 94,991 88,135 Competitions and bonuses 39,034 30,337 Convention and hiring expenses 26,264 14,800 Expenses — rolling stock 21,931 16,293 4.20 Mr Langelier maintained that the investigation never disclosed any vouchers for the expenses claimed by Mr Charles Marchand but that, in any event, he checked more than half of the company’s vouchers before allowing expenses for the total amount. 5. ...

It is obvious that there was no novation within the provision of the Quebec Civil Code because Mr Berco was not a party to the convention between Mr Berke and Mr Bock ad there is no evidence to show that Mr Berke was released of his debt towards Mr Berco. ...

Paragraphs 1 and 2 of the agreement read: (1) The Company hereby grants to the operator, in consideration of the payment set out in Schedule “A” hereof, for a period of ten (10) years or for as long as the operator shall fully and faithfully perform all of the covenants, terms and conditions herein contained by the operator to be performed, the exclusive right and license: (a) To operate a food take-out store at a location identified in schedule “B” hereof; (b) To use, in the conduct of the operator’s business hereunder, the Company’s distinctive labels, designs, cartons, containers, and any advertising matter pertaining to the business or the product used or sold therein and to display the name “Dixie Lee” upon the premises, equipment, stationery and advertising matter used in convention with the sale of products at the take-out store. ...

Having so found, it is not necessary for me to deal with section 115 of the Income Tax Act as proposed by counsel for the appellant, nor with the provisions of the Canada-US Tax Convention. ...

Paragraph 81(1)(a) of the Income Tax Act provides: 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; It was common ground that: The appellant is a status Indian, within the meaning of the Indian Act. ...

The definition of “eligible individual” in section 122.6 reads: “eligible individual” in respect of a qualified dependant at any time means a person who at that time (a) resides with the qualified dependant, (b) is the parent of the qualified dependant who primarily fulfils the responsibility for the care and upbringing of the qualified dependant, (c) is resident in Canada, (d) is not described in paragraph 149(1)(«) or (b), and (e) is, or whose cohabiting spouse is, a Canadian citizen or a person who (i) is a permanent resident (within the meaning assigned by the /mmigration Act), (ii) is a visitor in Canada or the holder of a permit in Canada (within the meanings assigned by the Immigration Act) who was resident in Canada throughout the 18 month period preceding that time, or (iii) was determined before that time under the Immigration Act, or regulations made under that Act, to be a Convention refugee, and for the purposes of this definition, (f) where the qualified dependant resides with the dependant’s female parent, the parent who primarily fulfils the responsibility for the care and upbringing of the qualified dependant is presumed to be the female parent, (g) the presumption referred to in paragraph (f) does not apply in prescribed circumstances, and (h) prescribed factors shall be considered in determining what constitutes care and upbringing. ...

Keeping has also been able to purchase approximately 80% of his family’s needs at wholesale through his Amway distributorship and he has attended out of province Amway Conventions at Niagara Falls and Atlanta, Georgia on a tax deductible basis. ...