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TCC

Akiwenzie v. The Queen, 2003 TCC 68 (Informal Procedure)

Income Tax Act 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; [30]     There is certainly no dearth of authorities on the issue of the situs of employment income for purposes of claiming the section 87 exemption. ...
TCC

S&F Philip Holdings Ltd. OP Sooke Harbour v. M.N.R., 2003 TCC 384

The collective agreement that governed the labour relations of the employees at the Château Frontenac at the relevant time stipulated that it was agreed that when the organizer of a function such as a convention or a banquet leaves tips to the hotel for distribution, eighty percent (80%) of these tips are to be distributed by the hotel to the employees governed by the collective agreement who have worked during these functions.               ...
TCC

Sero v. The Queen, docket 1999-2486-IT-G

(c) any amount received or receivable by the taxpayer in the year (depending on the method regularly followed by the taxpayer in computing the taxpayer's income) as, on account of, in lieu of payment of or in satisfaction of, interest to the extent that the interest was not included in computing the taxpayer's income for a preceding taxation year; 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; Indian Act 87. (1) Notwithstanding any other Act of Parliament or any Act of the legislation of a province, but subject to section 83, the following property is exempt from taxation, namely, (a) the interest of an Indian or a band in reserve lands or surrendered lands, and (b) the personal property of an Indian or a band situated on a reserve. (2) No Indian or band is subject to taxation in respect of the ownership, occupation, possession or use of any property mentioned in paragraph (1)(a) or (b) or is otherwise subject to taxation in respect of any such property. (3) No succession duty, inheritance tax or estate duty is payable on the death of any Indian in respect of any property mentioned in paragraphs (1)(a) or (b) or the succession thereto if the property passes to an Indian, nor shall any such property be taken into account in determining the duty payable under the Dominion Succession Duty Act, Chapter 89 or the Revised Statutes of Canada, 1952, or the tax payable under the Estate Tax Act, chapter E-9 of the Revised Statutes of Canada, 1970, on or in respect of other property passing to an Indian. ...
TCC

Salaison Lévesque Inc. v. The Queen, 2014 TCC 36

., chapter S-31.1. [27] [translation] This concept generally exempts businesses from investigating their co‑contractors prior to entering into a contract with them, in the interest of expediting business transactions and preventing them from being unduly disrupted by an expensive, impractical investigation process: definition from a paper by Paul Ryan on employment agencies at the 2012 Association de Planification fiscalet et financière Convention, Montréal, at p. 1. [28] See sections 217 and ff. ...
TCC

Groscki v. The Queen, 2017 TCC 249 (Informal Procedure)

Modern convention drops the separation feature of the comma in a list of items greater than two before the conjunction “and” or “or”. ...
TCC

Brenda Schaff v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2695

They are therefore illustrative of the meaning, in criminal or penal law, of“ "principles of fundamental justice"; they represent principles which have been recognized by the common law, the international conventions and by the very fact of the entrenchment of the Charter, as essential elements of a system for the administration of justice which is founded upon the belief in the dignity and worth of the human person and the rule of law. ...
TCC

Violette Motors Limited and W. H. Violette Limited v. Minister of National Revenue, [1987] 1 CTC 2205, 87 DTC 136

In 1968 as a result of adoption of the Auto Pact convention entered into between Canada and the United States of America the Canadian producers of Motor Vehicles could approvision themselves with vehicles produced in plants located in the United States without the payment of a customs duty. ...
TCC

1229-1605 Québec Inc. v. R., [1998] 3 CTC 2175, 98 DTC 1349

Couture, who was inexperienced in matters of organization and travel sales in general, spent all his available time learning and finding out about the rules, bases, conventions and principles that would enable him to manage the operations well enough to maximize the return on his investment. ...
TCC

D'Auteuil v. The King, 2023 TCC 3

Heeb, adhere to the required statistical conventions. [33] This expert, Dr. ...
TCC

Bérubé v. The King, 2023 TCC 12

Heeb, adhere to the required statistical conventions. [30] This expert, Dr. ...

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