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The Queen, 2016 TCC 69 (Informal Procedure)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 deduction for U.S. pension income deduction translated at exchange rate for year of receipt A Canadian-resident recipient of pension payments from a U.S. pension plan was entitled under Art. ...

Income Tax Convention did not detract from such reduction occurring "under this Act", and also indicated that he was not prepared to say that because the envisaged U.S. tax saving was greater than the envisaged Canadian tax saving established that the primary purpose of the transaction was not the avoidance of Canadian tax. ...

Income Tax Convention could not prevent Canada from applying GAAR to recharacterize the transaction as one to which section 84 applied. ...

The Queen, 2011 DTC 1053 [at at 297], 2011 TCC 25, aff'd 2011 DTC 5148 [at 6159], 2011 FCA 243-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 The taxpayer was a non-resident UK corporation operating in Canada through a permanent establishment. ...

The Queen, 2009 DTC 1705, 2009 TCC 435, aff'd 2010 DTC 5100 [at 6932], 2010 FCA 152-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Campbell J. found that the taxpayer's habitual abode was in Canada. ...

The Queen, 2008 DTC 3631, 2008 TCC 306-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. ...

The Queen, 2014 DTC 1040 [at at 2723], 2013 TCC 404-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 5-year limitation did not apply to secondary Part XIII assessment FCA appeal settled. ...

Income Tax Convention (a claim which, in this case, was unsupported by the evidence). ...

The Queen, 2006 DTC 2705, 2006 TCC 246-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 The taxpayer provided a fully-crewed vessel under a charter party to a Canadian resident company for the purpose of transporting pipe and other materials from Nova Scotia to two ships of the Canadian company laying pipe off the coast of Nova Scotia within the Sable Island offshore area. ...

The Queen, 2016 TCC 283 (Informal Procedure)-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 application of Art. 24 of Canada-U.S. ...