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Income Tax Convention (1980) would apply because she would be deemed to:...be a resident of the Contracting State in which [s]he has a permanent home available to [her]. [11] This would be the United States. [12] I mentioned in the course of argument Article XIX of the Canada-U.S. Income Tax Convention (1980) which reserves to Canada the exclusive right to tax salaries paid to Canadian citizens in respect of government services. ...

Business tax, fees, licences, dues,                 memberships, and subscriptions        $ 1,165.94 Interest 1,647.72 Meals and entertainment     210.76 Motor vehicle expenses       6,148.30 Office expenses     5,824.01 Travel                      9,624.09 Telephone and utilities        800.81 Convention expenses           8,687.37                 Subtotal 34,109.00 Capital cost allowance         2,639.21 Total business expenses     $36,748.21 [8]            Exhibit A-1 is a letter of October 3, 1990 from the placement agency Roevin Technical People Ltd. to Frontier Technical Services c/o the appellant Mr. ... It is wholly unrealistic and unreasonable to attempt to attribute, for example, $6,148.30 motor vehicle expenses, or $9,624.09 travel expenses, or convention expenses of $8,687.37, or office expenses of $5,824.01, or home office expenses of $3,226.10 to the work at Petro-Canada. ...

Nothing in Article XVII of the 1942 Canada-US Tax Convention can be read as imposing upon Canada an obligation to provide one tax dollar of Canadian relief for every dollar of tax imposed by the United States on its citizens. The assessment does not offend Article XV of the Convention. This Article establishes “... a mutual covenant to apply as between each country whatever foreign tax credit provision the respective domestic laws of each country might from time to time adopt....”.* [1] The respondent, in making the assessment in issue, has not imposed on the appellant any more burdensome tax than that which would be imposed on any citizen of Canada in like circumstances. ...

Income Tax Convention (1980) would apply because she would be deemed to: be a resident of the Contracting State in which [s]he has a permanent home available to [her]. ... Income Tax Convention (1980) which reserves to Canada the exclusive right to tax salaries paid to Canadian citizens in respect of government services. ...

Tax Convention, and that’s specifically Article 5 therein. The pension income, I’ve concluded, is a pension benefit within the meaning of Subsection 56(1)(a)(i) of the Income Tax Act, and the appellant is not entitled to a deduction of income pursuant to Paragraph 110(1)(f)(i) of the Act. That is, it was not an amount exempt from taxable income in Canada because of a tax convention. ...

The argument was that the requirement under the Income Tax Act that women such as the appellants must include in income such maintenance payments received for the support of their children discriminates against women in contravention of the Declaration on the Elimination of Discrimination against Women, the Convention on the Elimination of All Forms of Discrimination against Women and the United Nations Declaration of the Rights of the Child. ... In the circumstances it is not necessary for me to deal with the other arguments advanced by the appellants beyond observing that conventions and declarations of the type relied upon by the appellants here, even though signed by Canada, do not, unless implemented by statute, have the force of law in Canada so as to override domestic legislation, although they may be useful guides to interpretation. ...

Neufeld and the Midway Dental Clinic throughout her 1982 taxation year, and that the amounts claimed by her for convention and seminar expenses were not deductible from her employment income. ... Little information was provided at the hearing regarding the "convention" and the "seminar" but there was no substantial indication from the Minister that the attendance was not in a direct sense related to her work as a dental hygienist. I am satisfied that neither the convention expenses nor the seminar expenses would be clearly deductible items for Miss Bradford in her capacity as an "employee". ...

In the Canada/France Tax Convention, Article II, subsection 3(b) states:   3.         The existing taxes to which the Convention shall apply are in particular:             (a)        …   (b)        in the case of France, the income tax, the corporation tax, the tax on wages and salaries (regulated by the provisions of the  Convention  applicable, as the case may be, to business profits or to income from independent personal services) the solidarity tax on net wealth, and any withholding tax, prepayment or advance payment with respect to the aforesaid taxes, (hereinafter referred to as “French tax”).   ...

He arrived in Canada in July 1993 as a political Convention refugee (Exhibit A-1). He claimed political refugee status on April 16, 1996, and the Convention Refugee Determination Division found him to be a Convention refugee on April 18, 1996. ...

In that tax return, the appellant claimed an exemption from income tax on the salary she earned that year from her employment with the Mission on the ground that the salary was not taxable in Canada pursuant to article 19 of the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital ... On March 6, 2007, the appellant again wrote to the International Tax Services Office to ask to be relieved of the obligation to pay taxes in Canada because of the provisions of the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital.   12.    ... The decisions of the Federal Council on permanent missions and their staff members and the Federal Council on Swiss foreign policies are not agreements or conventions entered into by one or more foreign countries and do not have the force of law in Canada.   ...