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He attended meetings and conventions, listened to tapes and examined the literature supplied by Amway. ...

(i) 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, 7 The foregoing are all of the sections which are relevant in arriving at what this Appellant's taxable income is. ...

.-- any social assistance payment made on the basis of a means, needs or income test and included by reason of clause 56(1)(a)(i)(A) or paragraph 56(1)(u) in computing the taxpayer's income for the year or any amount that is (i) an amount 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 (ii) compensation received under an employees' or workers' compensation law of Canada or a province in respect of an injury, disability or death, except any such compensation received by a person as the employer or former employer of the person in respect of whose injury, disability or death the compensation was paid, (iii) income from employment with a prescribed international organization; 4 The appellant was a member of the Royal Canadian Mounted Police (the “R.C.M.P.”). ...

Analysis Paragraph 81(1)(a) of the Income Tax Act 7 Paragraph 81(1)(a) of the Income Tax Act codified the common law rule that amounts declared to be exempt from income tax by any other enactment of Parliament shall not be included in computing the income of a taxpayer. 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 the Parliament of Canada, 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. ...

Elijah was a Convention refugee under section 96 of the Immigration and Refugee Protection Act as he had a well-founded fear of persecution in Cameroon. [1] [4] Mr. ...

  [12]          At the 2005 convention of the Association de planification fiscale et financière, CRA was asked whether it had reviewed its position on the meaning of PUP in light of Klotz. [2] The CRA was still of the opinion that the way the property is used should be examined before making a determination. ... Kirvan                                                           Deputy Attorney General of Canada                                                           Ottawa, Canada             [1] 2004 TCC 147, affd. by 2005 FCA 158. [2] See the APFF's 2005 convention, conference No. 2005-0141261C6: [Translation] meaning of the words "personal-use property" and impact of Klotz. [3] 2005 FCA 386. [4] [1996] T.C.J. no. 1457 (QL), affd. by [1999] F.C.J. no. 1964 (QL). [5] [1994] 3 S.C.R. 3. [6] [1996] T.C.J. ...

.), he quotes the judgment in the Belgian Linguistic Case (No, 2) (1968), 1 E.H.R.R. 252, at page 284, which deals with article 14 of the European Convention on Human Rights, 23 U.N.T.S. 222, an article which secures rights without discrimination:...the principle of equality of treatment is violated if the distinction has no objective and reasonable justification. ... A difference in treatment in the exercise of a right laid down in the Convention must not only pursue a legitimate aim: Article 14 is likewise violated when it is clearly established that there is no reasonable relationship of proportionality between the means employed and the aim sought to be realised. ...

For the purposes of section 146 it is defined as follows, in paragraph 146(1)(c): 146(l)(c) "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), (B) a business carried on by the taxpayer either alone or as a partner actively engaged in the business, or (C) property, where such income is derived from the rental of real property or from royalties in respect of a work or invention of which the taxpayer was the author or inventor, (ii) an amount included under paragraph 56(1)(b), (c), (c.l), (g) or (o) in computing the taxpayer’s income for a period in the year throughout which the taxpayer was resident in Canada, (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) in the case of a taxpayer described in subsection 115(2), the aggregate that would be determined under paragraph (e) thereof in respect of the taxpayer for the year if (A) that paragraph were read without reference to subparagraphs (iii) and (iv) thereof, and (B) subparagraph (e)(ii) thereof were read without any reference therein to paragraph 56(1)(n), except any part thereof included in the aggregate determined under this paragraph by reason of subparagraph (iii) or 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, 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) an amount deductible under paragraph 60(b), (c) or (c.l) in computing the taxpayer’s income for the year, 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. ...

  « intermédiaire » Inscrit qui, agissant à titre de mandataire d’une personne ou aux termes d’une convention conclue avec la personne, permet à cette dernière d’effectuer une fourniture ou en facilite la réalisation. ... (Act)         « pièce justificative » Document qui contient les renseignements exigés à l’article 3, notamment : a) une facture; b) un reçu; c) un bordereau de carte de crédit; d) une note de débit; e) un livre ou registre de comptabilité; f) une convention ou un contrat écrits; g) tout registre faisant partie d’un système de recherche documentaire informatisé ou électronique ou d’une banque de données; h) tout autre document signé ou délivré en bonne et due forme par un inscrit pour une fourniture qu’il a effectuée et à l’égard de laquelle il y a une taxe payée ou payable. ...

Grassellini and 2 representatives, including the worker; (admitted) (e)         the worker began working for the Appellant on February 17, 2003 under a written contract of employment; (admitted) (f)          the contract of employment stipulated, among other things, that-the representative would work under the instructions of the sales manager and would submit a weekly report on her work, her calls, her interviews and information on the value of the orders taken during the week,-the representative agreed, as an integral part of her work, to attend all meetings of sales personnel, product presentations, conventions and other gatherings as directed by her immediate supervisor or other members of the management of the company,-the representative agreed to sell the merchandise and equipment distributed by the company exclusively at the list prices established by the company or at a special price established and approved by the company; (admitted with clarifications) (g)         the work of the worker consisted of: meeting customers in order to present the products to them and leave samples with them, take orders and deliver them to the office of the Appellant and deliver products when dealing with new customers; (admitted with clarifications) (h)         the worker did not have to adhere to a specific work schedule, but worked 40 hours a week; (admitted with clarifications) (i)          the worker prepared and gave to the Appellant a list of the customers that she visited and the orders that she wrote; (admitted) (j)          the worker was required to call on the customers designated by the Appellant and attend training courses when required to do so by the Appellant; (denied) (k)         the Appellant supplied the worker with samples of products, business cards, order forms and other supplies, while the worker provided her own vehicle and absorbed the operating costs; (admitted) (l)          the worker was to be remunerated on a commission basis, but, for the last 4 weeks of the period, she received $1,538.46 every 2 weeks, which the Appellant called "advances on commissions" whereas the contract stipulated that the representative was not entitled to advances on commission; (admitted with clarifications) (m)        the customers were customers of the Appellant and not of the worker; (denied) (n)         the duties of the worker formed part of the regular activities of the Appellant; (unknown) (o)         during the period at issue, the worker worked for 280 hours, i.e., 7 x 40-hour weeks; (unknown) (p)         during the period at issue, she received a total of $5,300.41 from the Appellant. ... Under the terms of this contract, the worker undertook to attend all meetings of the sales staff, product presentations, conventions and other gatherings. ...