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Pereira v. Canada (Citizenship and Immigration), 2019 FC 1413

The Applicant was recognized as a Convention refugee or person in need of protection in 2006, and she was granted permanent residence in Canada in 2007. [4] The Applicant acquired a passport from Singapore on March 29, 2008, which she renewed in April 2013 and March 2018. [5] The Applicant used her Singaporean passport to travel to Australia in October 2008 and to Singapore in November 2010. [6] With respect to her 2010 visit to Singapore, the Applicant claimed that she was visiting her sister and participating in the commemoration of the ﬁfth anniversary of her mother’s death. ...

Mercredi v. Canada (Citizenship and Immigration), 2019 FC 1425

In its decision, the RAD confirmed the decision by the Refugee Protection Division [RPD] that the applicant was not a Convention refugee or a person in need of protection under sections 96 and 97 of the Immigration and Refugee Protection Act, SC 2001, c 27 [IRPA]. [2] The applicant is a citizen of Haiti. ...

Her Majesty the Queen v. Thomas N Collins, [1984] CTC 592, 84 DTC 6292

I was also referred to The Canada-United States of America Tax Convention Act, 1943, which is to prevent double taxation, and prevent fiscal evasion, and includes the exchange of information between the two countries. ...

Lyle a Meredith v. Minister of National Revenue, [1980] CTC 2433, 80 DTC 1381

Further, in Ernest G Shekel v MNR, [1972] CTC 210; 72 DTC 6178, it was held that an Information Bulletin published by the Minister which misstated the effect of Article 8(a) of a Tax Convention did not create an estoppel against the Minister. ...

Zhikai Cai v. Her Majesty the Queen, [1996] 3 CTC 2724 (Informal Procedure)

Subparagraph 110(l)(f)(i) of the Act provides that a taxpayer may deduct an amount exempt from income tax in Canada because of a provision contained in a Tax Convention or Agreement with another country that has the force of law in Canada. ...

Erwin v. R., 98 D.T.C. 1330, [1998] 2 C.T.C. 2112

Tax Convention (1980) refers to Dependent Personal Services. It reads: 1. ...

Minister of National Revenue v. John James Armstrong, [1956] CTC 93

Nor if one refers to the French version was it ‘‘un montant payé par le contribuable pendant l’année, conformément à un décret, ordonnance ou jugement rendu par un tribunal compétent dans une action ou instance en divorce ou en séparation judiciaire, ou en conformité d’une convention écrite de séparation, à titre de pension alimentaire ou autre allocation payable périodiquement...”. ...

Furness (Pacific) Limited v. Minister of National Revenue, [1952] CTC 22, 52 DTC 1048

An alternative point raised by appellant was the question of double taxation, and Article XVI of the Canada-United States of America Tax Convention Act, 1943, was referred to. ...

2011 Ruling 2011-0395771R3 - 39(2) - Conversion of P/S to C/S

Our understanding of the facts, proposed transactions and the purpose of the proposed transactions is as follows: Definitions: "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date of this advance income tax ruling; "CAD" means Canadian dollars; "CBCA" means the Canada Business Corporations Act, as amended to the date of this advance income tax ruling; "Common Shares" means the common shares of the capital stock of Corp A; "Convention" means XXXXXXXXXX; "Corp Group" means XXXXXXXXXX; "Corp A" means XXXXXXXXXX, a corporation governed by the CBCA; "Corp B" means XXXXXXXXXX, a corporation resident in Country 1 for purposes of the Convention; "Corp C" means XXXXXXXXXX, a corporation governed by the laws of Country 1; "Corp D" means XXXXXXXXXX; "Corp E" means XXXXXXXXXX; "Corp F" means XXXXXXXXXX; "Country 1" means XXXXXXXXXX; "CRA" means the Canada Revenue Agency; "Exchange Rate" means the "noon rate" published by the Bank of Canada and used to convert the value of CAD into USD; "Preferred Shares" means the Series 1 preferred shares of the capital stock of Corp A, as described in paragraph 10; "Stated Capital" has the meaning assigned by section 26 of the CBCA; "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; and "USD" means United States dollars. ...

13 December 2011 External T.I. 2011-0416261E5 - Article XXII(4) of the Canada-U.S. Treaty

Reviewing the intention of the drafters of a taxation convention is a very important element in delineating the scope of the application of that treaty. ... The Queen, [1985] 1 C.T.C. 163, 85 D.T.C. 5188 (F.C.T.D.), at pages 166-67 (D.T.C. 5191): Contrary to an ordinary taxing statute a tax treaty or convention must be given a liberal interpretation with a view to implementing the true intentions of the parties. ...

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