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Income Tax Convention. ...

Expense- Know-How and Training Expenses incurred by the taxpayer, an Amway distributor, in attending "business training seminars" (characterized by the court as conventions) in Canada and the U.S. were found to be on capital account given that "the acquisition of new skills and increased knowledge by the attendees forms an integral part of those seminars" (p. 2119). ...

Expense- Lessening of Competition Expenses incurred by the taxpayer, an Amway distributor, in attending "business training seminars" (characterized by the court as conventions) in Canada and the U.S. were found to be on capital account given that "the acquisition of new skills and increased knowledge by the attendees forms an integral part of those seminars" (p. 2119). ...

The Queen, 2014 DTC 1046 [at at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275-- summary under Other/Conflicting Statutes Summary Under Tax Topics- Statutory Interpretation- Other/Conflicting Statutes presumption against inconsistency Before finding that there was no inconsistency in the taxpayer being resident in Canada for purposes of the Act and a resident of the U.K. for purposes of the Canada-U.K Income Tax Convention,, Rip CJ stated (at para. 67): In Friends of the Oldman River Society v. ...

The Queen, 2006 DTC 2076, 2005 TCC 812-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 The taxpayer was a U.S. resident who was employed by Air Canada as a pilot on domestic flights (between Toronto and other Canadian cities) and international flights (between Toronto and U.S. cities). ...

., 98 DTC 1124, [1998] 1 CTC 2217 (TCC)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The taxpayer was posted to Malaysia, where he lived in rented premises. ...

Minister of National Revenue, 91 DTC 704, [1991] 1 CTC 2473 (TCC)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 In addition to carrying on an orthodontic practice at various locations in the U.S., the taxpayer also maintained a professional office in Regina. ...

The Queen, 2011 DTC 1177 [at at 967], 2011 TCC 232-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 Pizzitelli J. found (at [paras. 102-103) that the limitation periods in Articles IX(3) and XXVII(3) of the Canada-Barbados Tax Treaty did not apply because the taxpayer was a Barbados International Business Company, which Article XXX expressly excludes from application of the Treaty. ...

The Queen, 2011 DTC 1177 [at at 967], 2011 TCC 232-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 Pizzitelli J. found (at [paras. 102-103) that the limitation periods in Articles IX(3) and XXVII(3) of the Canada-Barbados Tax Treaty did not apply because the taxpayer was a Barbados International Business Company, which Article XXX expressly excludes from application of the Treaty. ...

The Queen, 2004 DTC 2393, 2004 TCC 199 (Informal Procedure)-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 The taxpayer, who was a U.S. citizen resident in Canada, did not claim treaty benefits when filing his U.S. return, with the result that his U.S. ...