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Subparagraph 110(l)(f)(i) of the Act provides that a taxpayer may deduct an amount exempt from income tax in Canada because of a provision contained in a Tax Convention or Agreement with another country that has the force of law in Canada. ...

Tax Convention (1980) refers to Dependent Personal Services. It reads: 1. ...

All three experts were extremely well qualified to provide evidence with respect to the interpretation of the OECD Model Convention (Messrs. Vann and Arnold), the development of the OECD Model Convention and the United Nations Model Double Taxation (Mr. Vann), and the interpretation of the Canada-US Convention from an American perspective (Mr.  ...

Income Tax Convention. He further contends that the "disallowance of a deduction or use as a tax credit" for such Class 3 U.K. pension contribution violates the Canadian Charter of Rights and Freedoms by treating a Canadian citizen paying into a Canadian state pension differently than a Canadian citizen paying into a U.K. state pension. ... Convention. He recognizes that the receipt of his old age pension will be taxable as part of his worldwide income. ... The social security benefits were however tax exempt in the U.S. and at page 6 Judge Sobier stated: Paragraph 4(a) of the Convention allows a deduction in respect of income tax paid or accrued to the United States in respect of profits, income or gains which arise in the United States. ...

If that is so he may be able to invoke the competent authority procedures under the Canada-Japan Income Tax Convention (1986), as described in Information Circular 71-17R3. Paragraph 2 of the Protocol to the Canada-Japan Convention reads as follows: 2. With reference to paragraph 2 of Article 4 of the Convention, where an individual or a company is a resident of both Contracting States the question shall be settled by mutual agreement by applying the following rules: (a) in the case of an individual, (i) he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. ...

Income Tax Convention (1980) ("Convention"). Section 212.1 of the Act provides that where a non-resident person disposes of shares of a Canadian corporation to another Canadian corporation and the transferor and transferee do not deal at arm’s length, the amount by which the fair market value of any non-share consideration received by the non-resident person from the purchasing corporation exceeds the paid up capital of the company whose shares are sold, shall be deemed to be a dividend paid by the purchaser at the time of the disposition and to be received by the non-resident person at that time. ... Article X of the Convention reduces the amount of tax from 25 per cent to ten per cent where the recipient corporate shareholder owns ten per cent or more of the voting stock of the paying corporation. ... He then stated that Orange Julius staff members were brought to a convention in Minneapolis from August 9 through August 11, three days prior to the closing of the agreement, part of the purpose of which was to have the Canadian Orange Julius franchisees meet the DQC personnel so that they would be familiar with the people with whom they would subsequently be dealing. ...

MacDougall argues that his client’s centre of vital interests is more closely tied to Guyana, his country of birth, making the Appellant a resident of Guyana for the purposes of the Act under paragraph 4(2)(a) of the Canada‑Guyana Income Tax Convention (the "Convention"). ... Leckie, counsel for the Respondent, argues that the evidence should lead me to conclude as follows:   a)    The Appellant was residing or ordinarily resident in Canada during the 1999, 2000 and 2001 taxation years. b)    Alternatively, the Appellant is deemed to have been a resident of Canada for the 2000 taxation year because he sojourned in Canada for more than 183 days. c)    In the event of a finding by me that the Appellant was a resident of both countries, the tiebreaker rule in paragraph 4(2)(a) of the Convention makes the Appellant a resident of Canada for the purposes of the Act.   ...   [63]          In the event that I am wrong and Canada is the Appellant’s home in the same way Guyana is, I find that the tiebreaker rule in paragraph 4(2)(a) of the Convention makes him a resident of Guyana for the purposes of the Act. ...

ANALYSIS AND DECISION [18]          Subparagraph 110(1)(f)(i) of the Act exempts from Canadian income tax an amount exempt from income tax in Canada because of a provision contained in a tax convention or agreement with another country that has the force of law in Canada. ...

Finally, the appellant stated that he had often been absent from Quebec City for business trips, conventions, conferences or other reasons during the years in question, so that he did not occupy the apartment made available to him for more than 50 per cent of the time during the period and, moreover, on occasion the apartment was used, at such times and even when he was there himself, as temporary housing for journalists or other members of the Le Soleil organization passing through Quebec City. ...

Also Article 17 of the Canada‑United Kingdom Tax Convention does not assist the Appellant as it provides that pension payments arising in the U.K. and which are paid to residents of Canada are taxable in Canada ...