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Income Tax Convention require that the income of a U.S. citizen resident in Canada be separated into separate "items of income" for purposes of calculating the maximum amount that Canada will grant as a foreign tax credit. ...

FAITS Le XXXXXXXXXX, un jugement de divorce entérine une convention sur les mesures accessoires où le payeur (Monsieur) s'engage à verser à la bénéficiaire (Madame) et à son enfant une pension alimentaire de XXXXXXXXXX $ par mois. ...

Paragraph 67.1(2)(e) of the Act provides that the 50% limitation does not apply where: (a) the amount was not in respect of a conference, convention, seminar, or similar event; (b) the allowance would have been included in the employee's income but for subparagraph 6(6)(a)(i) of the Act; and (c) the amount is paid in respect of a work site in Canada that is not in an urban area of more than 40,000 people and is at least thirty kilometers from such an urban area. ...

With respect to her claim, Individual B was considered by the Court to have provided assistance in the administration and marketing roles, maintained the company accounts, attended XXXXXXXXXX conventions and, from time to time, Individual B would discuss ideas in respect of the business with Individual A. ...

Income Tax Convention (1980) (the "Canada-U.S. treaty") would be reduced from 25% to 10% by virtue of Article XII of the Canada-U.S. treaty. ...

Therefore, assuming Condition 1 of the QTHE definition is otherwise met, it is our view that the particular eligible entity may be a QTHE if the total of all amounts, each of which is the eligible entity’s qualifying revenue for the prior reference period for any of the first qualifying period to the thirteenth qualifying period (but including only one of the tenth qualifying period or the eleventh qualifying period) was earned primarily from providing equipment consulting services for conventions or similar events that fall within either or both of subparagraphs (b)(iv) or (xx) of subsection 8901.1(2) of the Regulations (i.e., Condition 2 is met). ...

Toutefois, si en vertu des termes de la convention relative à l'option d'achat d'actions, le droit à l'option du contribuable prend fin au moment de la cessation d'emploi, nous sommes d'avis que le montant reçu pour la perte de bénéfices dans un tel régime serait reçu à titre d'allocation de retraite. ...

On XXXXXXXXXX, an inspector of XXXXXXXXXX Tax Administration issued an English translation of a Declaration of residence ("XXXXXXXXXX ", "Declaration") to the effect that the Entity is a resident of XXXXXXXXXX within the meaning of article XXXXXXXXXX of the Convention for avoidance of double taxation between XXXXXXXXXX and Canada. 10. ...

Article 21 deems gains of a resident of Canada, which are taxed in Japan under the Convention, to arise from a source in Japan and requires Canada to provide a credit in respect of such Japanese tax against any Canadian tax payable on such gains (footnote 7) However, Article 21 does not apply in this case to re-source the deemed gain to Japan because the deemed gain was not taxed in Japan. ...

The conditions for the application of subsection 402(4.1) are as follows: (a) the destination of a shipment of merchandise to a customer to whom the merchandise is sold by a corporation is in a country other than Canada or the customer to whom merchandise is sold by a corporation instructs that the shipment of merchandise be made by the corporation to another person and the customer's office with which the sale was negotiated is located in a country other than Canada, (b) the corporation has a permanent establishment in the other country, and (c) the corporation is not subject to taxation on its income under the laws of the other country, or its gross revenue derived from the sale is not included in computing the income or profit or other base for income or profits taxation by the other country, because of (i) the provisions of any taxing statute of the other country, or (ii) the operation of any tax treaty or convention between Canada and the other country, If these conditions are met, paragraph 402(4.1)(d) modifies the rules found in subsection 402(4). ...