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In my view these gatherings could be categorized best, under the Income Tax Act, as conventions. ... Thus, expenses of attendance at the convention in Maine in 1978 is an allowable deduction, as are the expenses of attendance at the first two of the conventions in the U.S. attended in 1979. ... The claim regarding travel expenses to attend the first two conventions attended in the U.S. in 1979 is allowed. ...

  [61]            Article XIII (5) of the Canada-Austria Income Tax Convention reads as follows: 5. ...   [66]            The OECD model conventions, including the Canada-Austria Income Tax Convention, generally have two purposes – the avoidance of double taxation and the prevention of fiscal evasion. ... There is considerable merit in the opinion of Klaus Vogel, who says that the meaning of “double taxation” in a particular income tax convention is a matter that must be determined on the basis of an interpretation of that convention (Klaus Vogel on Double Taxation Conventions: A Commentary to the OECD –, UN –, and US Model Conventions for the Avoidance of Double Taxation on Income and Capital, 3 rd ed. ...

The assessment aforementioned violates the Conventions for the avoidance of double taxation between Canada and the United States of America and between Canada and France.” ... We have seen that receipts of this kind benefit from the tax exemption decreed by Article I of the Canada-United States Convention. ... Coming now to the second series of motion picture contracts, exhibits 6 to 10 inclusive, concerning which the Canada-France Income Tax Convention (1950-1951, S.C. 15, Geo. ...

For a proper consideration of said Articles, it is also necessary to have reference to the following definitions referred to in the Protocol to the Convention: 3. ... On this basis, he argues the Tax Convention would not apply at all since by Article I, the Convention applies only to relieve an enterprise of one contracting state from taxation by the other contracting state. ... By section 3 of the Canada-US Tax Convention Act, 1943, the terms of said Convention and Protocol have the force of law in Canada and must prevail over any other law to the extent of any inconsistency therewith. ...

At issue in this appeal is the proper interpretation to be accorded paragraph 212(5)(a) of the Income Tax Act and Article XIIIC of the Canada-United States Income Tax Convention, 1942. ... The Minister submits that video tapes of motion picture films are motion picture films for the purpose of subsection 212(5) of the Income Tax Act and Article XIIIC of the Canada-United States Income Tax Convention, 1942. ... Income Tax Act and the Canada- United States Tax Convention. Although video tape may be the method of presentation, the content nevertheless remains a motion picture film within the ordinary and commonly understood meaning of those words. ...

Indeed, she did not recall what convention she attended but she suggested it may have been in the United States. ... Concerning conventions and seminars: "Conventions are expensive". 4. ... She has been updating her knowledge through seminars and conventions, although the specifics are uncertain. ...

Drouin Deputy Attorney General of Canada Ottawa, Canada     [1] Exhibit R-1: Annual statements (English translation); Exhibit R-2: Annual statements (in Dutch). [2] Amended Reply to the Notice of Appeal, paragraph 10. [3] Amended Reply to the Notice of Appeal, paragraph 13(g). [4] Convention Between Canada and the Kingdom of the Netherlands, Article 2, paragraph 3. [5] Convention Between Canada and the Kingdom of the Netherlands, Article 18, paragraphs 1 and 2. [6] Convention Between Canada and the Kingdom of the Netherlands, Article 22, paragraph 5(a). [7] Income Tax Act, subsection 126(1). [8] Convention Between Canada and the Kingdom of the Netherlands, Article 22, paragraph 6(b). [9] Income Tax Act, subparagraph 56(1)(a)(i). [10] Béliveau v. The Queen, 2018 TCC 87 at paragraphs 14, 22, and 24. [11] Exhibit R-2: Annual statements (in Dutch). [12] Exhibit R-1: Annual statements (English translation). [13] Convention Between Canada and the Kingdom of the Netherlands, Article 22, paragraph 6(b). [14] Amended Reply to the Notice of Appeal, paragraph 13. ...

Indeed, she did not recall what convention she attended but she suggested it may have been in the United States. ... Concerning conventions and seminars: “Conventions are expensive”. 4. Concerning depreciation: “Probably my computer”. 5. ... She has been updating her knowledge through seminars and conventions, although the specifics are uncertain. ...