Search - convention

The appellant attended a convention trip to Greece under the auspices of Hupp (Canada) Limited (hereinafter referred to as “Hupp”). ... The appellant attended the convention at the request of Frontier and as one of its employees. ... He was simply requested to attend the convention by the President and General Manager of the company for business reasons, which included goodwill and public relations. ...

While the purpose of the Convention is to avoid double taxation and, as counsel for the appellant argued, while the Convention is to be reciprocal, there will still be provisions of United States and Canadian law that will yield different results in their application for Canadian and United States' taxpayers. ... Thus, perfect symmetry will not be achieved by the 1980 Convention. [3]      While the Technical Explanation of the 1980 Convention refers to "total gain", this phrase cannot be read in isolation. ... The 1980 Convention provides for either valuing property as of December 31, 1984, i.e. ...

Succinctly stated, the issue to be decided is whether a lump sum payment received by the appellant taxpayer, an American citizen and resident of Canada, is exempt from taxation in Canada by reason of the Canada-United States Income Tax Convention (1980), as amended (the “Convention”). ... Treasury Department and released on 26 April 1984, four years after the Convention was signed. ... However, the purposes of the Convention are not so limited, even though the preamble to the Convention goes no further. ...

This makes the meaning of this subsection clearer and closer to what is the purpose of all such conventions. ... The Vienna Convention on the Law of Treaties, to which both Canada and the Netherlands are parties, contains the general rules of interpretation of international conventions. ... The amendments made in 1962 and 1965 to the Canada Income Tax Act (supra) contravene the provisions of the Canada-Netherlands Income Tax convention and are therefore ineffective to abrogate the provisions of Article IV(5) of such convention. ...

The estate claimed exemption from taxation pursuant to Article VIII of the Canada-US Tax Convention. ... There are twenty-six concluded and ten proposed tax conventions, treaties or agreements between Canada and other nations of the world. ... Article 31 of the Vienna Convention on the Law of Treaties (1969) to which Canada subscribed governs the general rule of interpretation to be applied. ...

Where any greater relief from tax would have been afforded by any provision of the 1942 Convention than under this convention, any such provision shall continue to have effect for the first taxable year with respect to which the provisions of this Convention have effect under paragraph 2(b). ... The OECD also publishes Commentaries on provisions of the OECD Convention. ... The introduction to the Commentary stated that the Committee “considered that existing conventions should, as far as possible, be interpreted in the spirit of the revised Commentaries, even though the provisions of these conventions did not include the more precise wording of the 1977 Model Convention”. ...

Exclusion par application de la Convention sur les réfugiés Exclusion — Refugee Convention 98 La personne visée aux sections E ou F de l’article premier de la Convention sur les réfugiés ne peut avoir la qualité de réfugié ni de personne à protéger. 98 A person referred to in section E or F of Article 1 of the Refugee Convention is not a Convention refugee or a person in need of protection. Irrecevabilité Ineligibility 101 (1) La demande est irrecevable dans les cas suivants : 101 (1) A claim is ineligible to be referred to the Refugee Protection Division if […] … d) reconnaissance de la qualité de réfugié par un pays vers lequel il peut être renvoyé; (d) the claimant has been recognized as a Convention refugee by a country other than Canada and can be sent or returned to that country; Convention des Nations Unies relatives au statut des réfugiés United Nations Convention Relating to the Status of Refugees Article premier.- Définition du terme "réfugié" Article 1- Definition of the term "refugee" E. ... This Convention shall not apply to a person who is recognized by the competent authorities of the country in which he has taken residence as having the rights and obligations which are attached to the possession of the nationality of that country. ...

Tax Convention (the "convention"), he is entitled to a complete exemption from taxation in Canada of his U.S. source pension income. ... The respondent further points out that attached to the convention is such an instrument referred to in paragraph 2(b), being the Technical Explanation of the the Canada—U.S. Convention (the “technical explanation”) of article XVIII of the convention together with an example. ...

They also were required to attend and participate in meetings, seminars, conventions, and promotional events in various locations, including in the United States. ... Nickerson is entitled to deduct: $3,729 for the bus hired to transport their team to a “major convention” in Ottawa; [7] $368.80 for attendance at a “major convention” in Massachusetts for which he was a speaker; [8] and $274.64 for a corn maze promotional event. [9] [22] The Respondent argues that some of the above convention expenses should not be allowed because subsection 20(10) of the Income Tax Act limits business expense claims to two conventions in a taxation year. While the Respondent relied on a compelling authority this regard, [10] I was not provided with evidence outlining the two conventions for which expenses had already been allowed for each taxation year. ...

On March 4, 1942, a Convention and Protocol was agreed upon by the two countries. ... The Convention entered into between Canada and the United States of America, set out in Schedule A, is approved and declared to have the force of law in Canada, and shall be deemed to be included in and to form part of the Convention and Protocol set out in the Schedule to The Canada-United States of America Tax Convention Act, 1943. ... On my reading of the Tax Convention, I should have also reached the conclusion that the denial of the foreign tax deduction for the earlier years as authorized by Section 38(1) of the Act also offended Article XV (1) of the Convention. ...