Search - convention

I-5, as amended provide as follows: 2(1) "reserve" means a tract of land, the legal title to which is vested in Her Majesty, that has been set apart by Her Majesty for the use and benefit of a band, and... 87. (1)      Notwithstanding any other Act of Parliament or any Act of the legislature of a province, but subject to section 83, the following property is exempt from taxation, namely, the interest of an Indian or a band in reserve lands or surrendered lands; and the personal property of an Indian or band situated on a reserve. 90. (1)      For the purposes of sections 87 and 90, personal property that was purchased by Her Majesty with Indian moneys or moneys appropriated by Parliament for the use and benefit of Indians or bands, or given to the Indians or to a band under a treaty or agreement between a band and Her Majesty, shall be deemed always to be situated on a reserve. [4]            The link with the Income Tax Act is paragraph 81(1)(a) which provides: 81. (1)      There shall not be included in computing the income of a taxpayer for a taxation year, (a) an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada; [5]            In Dixon v. ...

He attended meetings and conventions, listened to tapes and examined the literature supplied by Amway. [4] He explained that for no personal reasons but simply to improve the Amway business he moved from his home in Humboldt, Saskatchewan (population 5,000) to Saskatoon (population approximately 180,000). ...

The appellant testified that in July of 1995 she attended at a music teachers' convention in Saskatoon. ...

This may not be convention but I believe it is reasonable. Signed at Ottawa, Canada, this 18th day of January 2016. ...

Scheinberg contends that, although his salary and the $4,000 grant together with $21.97 (a royalty received from Garland Publishing) should be included in computing his income, the following expenses should be deducted: TRANSPORTATION: $1,501.50 TELEPHONE: $1,776.00 PROMOTION: 2340 X 80 per cent: $1,872.00 CONVENTION: $3,000.00 DUES AND MEMBERSHIPS: $650.00 TRAVEL: $5,000.00 BANK CHARGES: $120.00 PROFESSIONAL FEES: $600.00 RESEARCH AND PRINTING: $20,000.00 $34,519.50 The Minister of National Revenue in assessing disallowed the expenses claimed to the extent of $30,497, the difference between the research grant plus the royalty and the expenses of $34,519.50 claimed on the basis that the research expenses allowable may not exceed the total research grants taxable in the year within the meaning of paragraph 56(1)o) of the Act. ...

—"earned income” of a taxpayer for a taxation year means the amount, if any, by which the aggregate of all amounts each of which is (i) the taxpayer's income for a period in the year throughout which the taxpayer was resident in Canada from (A) an office or employment, determined without reference to paragraphs 8(1)(c), (m) and (m.2), (iii) the taxpayer's income for a period in the year throughout which the taxpayer was not resident in Canada from (A) the duties of an office or employment performed by the taxpayer in Canada, determined without reference to paragraphs 8(1)(c), (m) and (m.2), or (B) a business carried on by the taxpayer in Canada, either alone or as a partner actively engaged in the business except to the extent that the income is exempt from income tax in Canada by reason of a provision contained in a tax convention or agreement with another country that has the force of law in Canada, or (iv)... exceeds the aggregate of all amounts each of which is (v) the taxpayer's loss for a period in the year throughout which the taxpayer was resident in Canada from (A) a business carried on by the taxpayer, either alone or as a partner actively engaged in the business, or (B) property, where such loss is sustained from the rental of real property, (vi)...or (vii) the taxpayer's loss for a period in the year throughout which the taxpayer was not resident in Canada from a business carried on by the taxpayer in Canada, either alone or as a partner actively engaged in the business, and, for the purposes of this paragraph, the income or loss of a taxpayer for any period in a taxation year is the taxpayer's income or loss computed as though that period were the whole taxation year; 146(1)(g.1) “RRSP deduction limit”. ...

The Queen, [1975] C.T.C. 126; 75 D.T.C. 5069, at 133 (D.T.C. 5073), Collier, J. dealt with the word "retirement" and subsection 31A(d) of the Canada-United States of America Tax Convention Act, 1943, which refers to the taxability of "a payment made by an employer to an employee or former employee upon or after retirement in respect of loss of office or employment”. ...

Appeal allowed. 1 *If the appellant is liable under subparagraph 212(1)(d)(i), the rate applicable to him is 15 per cent under the Canada-United States Tax Convention in existence at the time rele vant to this appeal. ...

Further at 447 [6315], Mr Justice Walsh concluded as follows: In the absence of any provision of Canadian Tax Law or any Convention between Canada and the United Nations which would allow the deduction claimed, I must regretfully maintain the appeals even though in the result both Defendants Lloyd Herman and Stephanie Herman are required to pay income tax on the full pension benefits received by them from the United Nations without having previously benefited by any tax deductions resulting from the amounts contributed by them towards these pensions. ...

. $3,784.24, $2,416.73, $6,170.10 and $3,756.88 allowed by the Minister in the 1990, 1991, 1992 and 1993 taxation years, were not incurred, or if incurred, were not incurred by the Appellant for the purpose of carrying on the research work, but were personal or living expenses of the Appellant; Expenses for Professional Assistance (aa) in the 1990, 1992 and 1993 taxation years, the Appellant deducted the amounts of $1,021.18, $1,321.36 and $623.19 respectively, as expenses for professional assistance in computing his net research income; (ab) in the 1990 taxation year, the Appellant incurred convention expenses of $629.77; (ac) in the 1992 taxation year, the expenses of $930.00 were claimed twice by the Appellant or were incurred by other persons; (ad) in the 1993 taxation year, the expenses of $623.19 were incurred by other persons; (ae) the documentation provided by the Appellant did not substantiate the total expenses for professional assistance claimed by the Appellant; (af) the expenses for professional assistance, in excess of the amounts i.e. $121.18 and $41.36 allowed by the Minister in the 1990 and 1992 taxation years, were not incurred, or if incurred, were not incurred by the Appellant for the purpose of carrying on the research work. ...