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Income Tax Convention could not prevent Canada from applying GAAR to recharacterize the transaction as one to which section 84 applied. ...

Subsequently, the Minister entered into agreements with the taxpayer to settle its income tax liability for 2004-2006, based on mutual agreement with the United States taxing authorities under Articles IX and XXVI of the Convention. ...

He would have been entitled to relief under Art. 23 of the UK-US Double Tax Convention from UK tax on such profits if the UK tax was "computed by reference to the same profits or income by reference to which the United States tax [was] computed. ...

Arguments based on Articles 6 and 8 of the European Convention on Human Rights were also rejected. ...

Morris, 2010 DTC 5013 [at at 6575]-- summary under Subsection 116(2) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(2) A decision of the Federal Court below to require the Minister to provide the taxpayer (a trust that allegedly was resident in Barbados for purposes of the Canada-Barbados Income Tax Convention and which had disposed of shares of a Canadian corporation) with a written decision as to whether the shares were treaty exempt property, based on a conclusion of the court that the taxpayer was resident in Barbados and not a resident of Canada, was reversed. ...

The Queen, 2011 DTC 1053 [at at 297], 2011 TCC 25, aff'd 2011 DTC 5148 [at 6159], 2011 FCA 243-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 The taxpayer was a non-resident UK corporation operating in Canada through a permanent establishment. ...

The Queen, 2009 DTC 1705, 2009 TCC 435, aff'd 2010 DTC 5100 [at 6932], 2010 FCA 152-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Campbell J. found that the taxpayer's habitual abode was in Canada. ...

The Queen, 2008 DTC 3631, 2008 TCC 306-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. ...

Dudney, 2000 DTC 6169 (FCA)-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 The taxpayer (a U.S. resident) provided his services, as independent contractor, to a nonresident corporation which, in turn, was hired by a Canadian company ("PanCan") to assist it in creating a computer system. ...

The Queen, 2014 DTC 1040 [at at 2723], 2013 TCC 404-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 5-year limitation did not apply to secondary Part XIII assessment FCA appeal settled. ...