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Shaver v. The Queen, 2003 DTC 2112, 2004 TCC 10 -- summary under Subsection 20(10)

Accordingly, in my view, these seminars are conventions...." Words and Phrases convention ...

Rodrigue v. Canada (Attorney Général), 2001 DTC 5296, 2001 FCA 157 -- summary under Article 18

Canada (Attorney Général), 2001 DTC 5296, 2001 FCA 157-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 In rejecting a submission of the taxpayer that he was entitled to a deduction for a contribution to a pension plan in the United States that was not registered by the Minister of National Revenue, the Court found (at p. 5297) that the phrase "income accrued" in paragraph 7 of Article XVIII of the Canada-U.S. Convention were "clearly meant to exempt only income earned on money in the plan, not contributions of capital made into the Plan. ...

Anson v. HMRC, [2015] UKSC 44 -- summary under Article 3

HMRC, [2015] UKSC 44-- summary under Article 3 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 3 scheme in Treaty article for allocating income between jurisdictions amounted to a definition of "source" In rejecting the Commissioners' argument that article 3(2) of the 1975 U.K-U.S. Convention required the term "sources" as used in article 23 thereof to be given the meaning which it bore under U.K tax law, Lord Reed stated (at para. 100): [A]rticle 23(3) explains how the source of profits or income is to be determined for the purposes of article 23, and that explanation is unrelated to the source doctrine of UK tax law. ...

Cloutier v. The Queen, 2003 DTC 317 (TCC) -- summary under Article 19

The Queen, 2003 DTC 317 (TCC)-- summary under Article 19 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 19 The taxpayer, who was a U.S. citizen and a resident of Canada, was not exempt under Article XIX on employment income earned by her as a teacher in the United States. ... Convention was intended to deal with citizens working abroad in the discharge of a governmental function. ...

Sun Life Assurance Co. of Canada v. Pearson, [1984] BTC 223 (HC), aff'd [1986] BTC 282 (C.A.) -- summary under Article 25

.)-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 The fact that a British branch of a Canadian life insurance company faced a higher level of taxation than the branch would have faced had it been an enterprise resident in the U.K. did not constitute discrimination. ... Conventions are "designed to preclude and nullify specific provisions which discriminate against a branch", and the U.K. branch- tax provisions were not objectionable in that sense. ...

5 October 2012 Roundtable, 2012-0451231C6 F - Gifts to American charities -- summary under Article 21

Convention Does Art. XXI, para. 7 of the Canada-U.S. Convention allow charitable foundations as defined in s. 149.1(1) to make donations to U.S. charitable organizations that are exempted under IRC s. 501(c)(3)? [P]aragraph 7 of Article XXI of the Convention does not allow for a U.S. charity to be treated as a "qualified donee" within the meaning of subsection 149.1(1). Consequently, Article XXI, paragraph 7, of the Convention does not allow charitable foundations to make donations to U.S. charities. ...

[ValueClick case], FR: CE, 11 Dec. 2020, Case No. 420174 (Conseil d'État [French Supreme Administrative Court]) -- summary under Article 5

[ValueClick case], FR: CE, 11 Dec. 2020, Case No. 420174 (Conseil d'État [French Supreme Administrative Court])-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 French staff who lined up the contracts (albeit “automatically” signed elsewhere) gave rise to dependent-agent PEs A wholly-owned Irish subsidiary ("ValueClick Ireland") of ValueClick Inc. ... In affirming the position of the French tax authorities that Value-Click Ireland had a dependent-agent permanent establishment in France as per Art. 2(9) of the Ireland-France Convention, the Supreme Administrative Court stated (at paras. 4-5, TaxInterpretations translation): 4. ... It follows from what has been said in paragraph 4 that the court committed an error of law and an error of legal characterization in holding, on the grounds that the contracts with the French clients were signed, under the conditions referred to above, by the Irish company, that the French company was not, for it, a permanent establishment within the meaning of (c) of article 2.9 of the Franco-Irish Convention. ...

28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation -- summary under Subsection 20(10)

28 April 2010 External T.I. 2009-0347581E5 F- Frais de formation-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) convention expenses providing an enduring benefit may be deducted within the s. 20(10) limitations When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible, CRA stated: Training costs are not deductible as current expenses and are considered to be capital expenditures under paragraph 18(1)(b) if the training course to which they relate provides a lasting benefit to the taxpayer. … As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ... In addition, a convention does not become a training course when some of its sessions take the form of workshops. Although convention expenses may provide a lasting benefit to the taxpayer, the taxpayer may deduct these expenses in computing income under subsection 20(10), subject to the limitations contained in that subsection. ...

16 May 2018 IFA Roundtable Q. 1, 2018-0748181C6 - New U.S. GILTI Tax -- summary under Article 29

Tax Convention (“Convention”), business profits of a corporation resident in Canada that does not have a permanent establishment in the U.S. shall be taxable only in Canada. Will CRA agree to accept requests for competent authority relief under Article XXVI of the Convention on the basis that the taxes imposed under the GILTI rules may be in violation of Article VII? ... XXIX(2) the Convention cannot affect the taxation by the US of its own residents, except to the extent provided in Para. ...

25 May 2004 External T.I. 2003-0051291E5 F - Formation et croisière -- summary under Subsection 20(10)

25 May 2004 External T.I. 2003-0051291E5 F- Formation et croisière-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) costs of cruise, if not viewed as training, would be non-deductible as they were incurred outside Canada Are expenses incurred by members of an Association respecting conventions, symposia and seminars held during a cruise deductible from their income? CRA noted that IT-357R2, para. 9 indicates that training is aimed at learning a subject in accordance with a formal course of study, whereas a convention is a formal meeting of members of an organization for professional or business purposes. ... CRA then stated: Assuming that the expenses [instead] are incurred in connection with a convention held during a sea cruise, it is our view that no amount for expenses incurred to attend the convention would be deductible since the convention would be held outside the geographical boundaries of the association that is the sponsor of the convention, as discussed in paragraph 2 of IT-131R2. ...

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