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Income Tax Convention (1980) (the Convention). It is agreed between the parties that the Appellant was a resident of the United States of America, and not a resident of Canada, during all of the relevant time period. ... The expression “fixed base” is not defined in either the Convention or the Income Tax Act (the Act). ... Otherwise, why would the Convention use different words in the two Articles? ...

That is, during this period he was a resident of Canada for purposes of the Act and a resident of Australia for purposes of the Convention. ... There do not appear to be specific rules in either the Convention or the Act regarding how to compute the tax in these circumstances. ... The Minister then applied Article XVIII of the Convention to determine the tax payable on the Pension income (Step 2). ...

In particular, she asserted her right to the protection of the provisions of the Canada- United States Tax Convention Act, 1984... ... INCOME TAX CONVENTION, (1980) [3] [26]Article IV, applying, as described above, reads as follows: Article IV- Residence 1.      ... Income Tax Convention (1980). Articles 31 and 32 of the Vienna Convention on the Law of Treaties (Can. ...

Zong eligible for relief against double taxation under the Convention. ... Zong entitled to relief against double taxation under the Convention? ... The general purpose of the Convention is to prevent double taxation. [9] Because the amount has not yet been subject to tax in the UK (because it has been deducted from income before calculating income tax) there is no requirement under the Convention or section 126 of the Act to provide relief in Canada. ...

Nonis’ remedy, if any, lies to the south [33] The Canada-United States Tax Convention was entered into, inter alia, to prevent double taxation, fiscal avoidance and fiscal evasion. ... This is also how this Court and others have interpreted Article XXIV of the Canada-United States Tax Convention. [38] Accordingly, there is no basis under Canada-United States Tax Convention to allow the appeal by vacating the assessments. Canada was within its rights under the Canada-United States Tax Convention to assess tax on the amounts received by the Appellant from MLSE in 2015 and 2016. ...

Income Tax Convention (1978) (the " Convention "); and j)               none of the Pension Benefits received by the Appellant in 1998 from the CFA were exempt from income tax in Canada by virtue of a provision contained in the Convention. ... Income Tax Convention also provides inclusions for the word "pension". ... The Appellant is therefore subject to the Tax Convention. [21]          As has been noted in Merritt v. ...

Further, the CRA’s position ignores the fact that the Crown Forest decision states that tax conventions must be interpreted by reference to the purpose and intention of the parties to the convention. ... Tax Convention as to the non‑taxable entities included as a “resident”. ... Tax Convention.   2.  In the alternative, the taxpayer states that it understands that amendments to the Canada-US Tax Convention will be announced shortly and said amendments will provide treaty protection to LLC’s. ...

This is obvious from the text of Article 2 of the Convention and of the OECD Model. ... This is another indication that the Convention does not apply to the HKSAR. ... Baker, Double Taxation Conventions and International Tax Law, 2 nd ed. ...

In that convention the phrase is defined as follows:   Article 2   1.         ... The Convention on Social Security between Canada and the Swiss Confederation came into force on October 1, 1995. It is my opinion that the phrase “social security legislation” has the same meaning in both the 1998 Convention and the Convention on Social Security between Canada and the Swiss Confederation. ...

Nightingale’s agent, would not be taxed in the United States due to their danger pay laws and also not taxed in Canada due to the application of Article XV of the Canada–United-States Income Tax Convention (1980) (the “ Convention ”); and   ii)  as a civilian Canadian versus Canadian military and police who are not taxed in Canada in accordance with subparagraph 110(1)(f)(v) of the Act.   ... Bowerman argues that Article XV of the Convention permits the United States to tax Mr. Nightingale, even though a Canadian resident, because his employment was, in accordance with Article XV of the Convention, "exercised" in the United States. ...