Search - convention

Procedural History [5]   The Refugee Protection Division [RPD] heard the Applicants’ claims and concluded they were not Convention Refugees in a decision published August 29, 2016. ... They argue that returning the Applicants would be contrary to the Canadian Charter of Rights and Freedoms and the Convention Against Torture. ...

.), (the Act), apply the appropriate international tax convention provisions, and release the sum of $5,350,603 held for the applicant's account. ... The applicant requested that a certificate be issued without any payment of tax on its part, on the grounds that under subsection 14(4) of the Canada-Barbados Income Tax Convention (the treaty), any capital gain resulting from its disposition of the shares is taxable exclusively in Barbados. [6]      Beginning in October 1998, the International Audit Section of the CCRA began requesting additional information and documents from the applicant for the purpose of determining the application of the General Anti-Avoidance Rule (GAAR). ...

THE NOTICE OF APPLICATION [3]           In the Notice of Application, the Applicant seeks, inter alia:... judicial review of acts or proceedings, including administrative action of the Canada Revenue Agency, (the “CRA”) as directed by the Minister of National Revenue (the “Minister”), including persons acting on his behalf and having, exercising, or purporting to exercise jurisdiction or powers conferred under the Income Tax Act (Canada) (the “ITA”) and the Canada United States Income Tax Convention (1980), as amended (the “Treaty”) ...

Then, it submits that the CRA has not shown why it needs this information or that it is relevant for the purpose of administering the Act. [19]            The Applicant argues that these Notices are in conflict with the provisions of the Convention Between Canada and the United States of America With Respect to Taxes on Income and Capital, 31 August 1984, Can. ...

. … […] The other comes from the case law of Suresh: 98   In our view, it may safely be concluded, following the International Convention for the Suppression of the Financing of Terrorism, that “terrorism” in s. 19 of the Act includes any “ act intended to cause death or serious bodily injury to a civilian, or to any other person not taking an active part in the hostilities in a situation of armed conflict, when the purpose of such act, by its nature or context, is to intimidate a population, or to compel a government or an international organization to do or to abstain from doing any act ”.   ...

In addition, if a refugee protection officer recommends that the Board allow a claim without a hearing, the Board may do so only if the case does not disclose any issues that should be brought to the Minister’ s  attention, the claimant’ s  identity has been sufficiently established, there are no serious issues of credibility involved, the claimant’ s  account of events is consistent with information on conditions in the country of origin, and the claimant has established that he or she meets the definition of a Convention refugee or a person in need of protection (Refugee Protection Division Rules, SOR/2002-228 (RPD Rules),  s. 19(4)(a)-(d)). ...

Jaballah was found to be excluded from refugee protection by Article 1F(a) of the United Nations Convention Relating to the Status of Refugees as being inadmissible to Canada on security grounds described in paragraphs 34(1)(b), (c), (d) and (f) of the IRPA. [7]   Since that time Mr.  ...

Convention on International Trade in Endangered Species of Wild Flora and Fauna [27]   Ratified in 1975, the Convention on International Trade in Endangered Species of Wild Flora and Fauna [CITES] is an international treaty which protects the trade of certain species of wild animals and plants from over-exploitation. ... In their recommendation letter to the Minister, ECCC officials only introduced issues related to CITES and international trade as an additional source of information about the principles of conservation, as required by NILCA. [134]   The Respondent AG of Canada further argues that the Minister did not err in considering issues related to CITES as the Convention does not contradict the principles established in NILCA. ...

In addition, the specific issues Kerry Canada was willing to subject to late reassessment were adequately identified. [58]   The CRA’s Audit Manual recognizes implied waivers: Implied Waiver When a waiver has not been filed in the prescribed form, the CRA will accept a written request for adjustment as being an implied waiver for the purpose of subparagraph 152(4)(a)(ii) of the ITA provided: •   the requested adjustment favours the taxpayer; •   the delay in processing the request for adjustment was not attributable to the taxpayer; and •   the essential information required in the prescribed waiver is included. [59]   In my opinion, the statements by Kerry Canada in the Part I Objections and Second CA Request fall within the parameters of the Audit Manual. [60]   Information Circular IC 71-17R5- Guidance on Competent Authority Assistance under Canada’s Tax Conventions (IC 71-17R5), addresses the implementation of CCA decisions and the issue of waiver as follows: 42. ...

. ·          “twinning arrangement” « convention de jumelage » “twinning arrangement” means the pairing of two distinct film or video productions, one of which is a Canadian film or video production and the other of which is a foreign film or video production. ...