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TCC

Robinson v. The Queen, 2010 TCC 649 (Informal Procedure)

  [53]          Relevant Legislation   Property exempt from taxation   87. (1) Notwithstanding any other Act of Parliament or any Act of the legislature of a province, but subject to section 83 and section 5 of the First Nations Fiscal and Statistical Management Act, the following property is exempt from taxation: …   (b) the personal property of an Indian or a band situated on a reserve.     81. (1) Amounts not included in income-- There shall not be included in computing the income of a taxpayer for a taxation year,   (a) statutory exemptions [including Indians]-- an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada;   Analysis   [54]          The Supreme Court of Canada in R. v. ...
TCC

Jeddore v. The Queen, docket 96-2182-IT-G

(a)            an amount that is declared to be exempt from income tax by any other enactment of the Parliament of Canada, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada. ...
SCC

Figueroa v. Canada (Attorney General), 2003 SCC 37, [2003] 1 SCR 912

The Constitution gives the Governor General the formal power of selecting the Prime Minister and Cabinet, but by convention she invariably appoints the leader of the party that has won the majority of seats in Parliament (assuming that there is one) as Prime Minister, and follows his recommendations in appointing the other ministers (see Hogg, supra, at p. 255; H. ...
TCC

Canadian Imperial Bank of Commerce v. The Queen, 2019 TCC 79, aff'd 2021 FCA 96

N Amer. a certificate or voucher presented as a gift and exchangeable for a specified value of goods, usu. at a specific store. 24   In the Ninth New Collegiate Dictionary, A Merriam-Webster, 1986, the definition of the phrase “gift certificate” is as follows: gift certificate n (1942): a certified statement entitling the recipient to select merchandise in the establishment of the issuer to the amount stated thereon 25   In ascertaining the import of section 181.2 of the Excise Tax Act, it is useful to keep in view the provisions of section 13 of the Official Languages Act, which reads: Any journal, record, Act of Parliament, instrument, document, rule, order, regulation, treaty, convention, agreement, notice, advertisement or other matter referred to in this Part that is made, enacted, printed, published or tabled simultaneously in both languages, and both language versions are equally authoritative. ...
TCC

Damis Properties Inc. v. The Queen, 2021 TCC 24

In this case, the transfer occurred in two steps and therefore it is necessary to identify the “precise point in time” [52] that the transfer occurred. [144] When interpreting legislation, “[i]t is assumed that the legislature is an accomplished user of language and has fully mastered the linguistic conventions through which meaning is communicated to an audience”. [53] It is therefore instructive to consider the grammatical meaning of the text used by the legislature. [145] The preamble uses the phrase “has transferred”. ...
TCC

Fiera Foods Company v. The King, 2023 TCC 140

For example, the definitions of “builder”, “charity”, “consumer”, “convention”, “debt security”, “financial service”, “money” and “office”. [184] See, generally, the presumptions regarding legislative drafting described in Ruth Sullivan, Statutory Interpretation, 3rd ed (Toronto: Irwin Law Inc, 2016), at page 129, particularly the third presumption. [185] See, for example, Walker v Ritchie, 2006 SCC 45 at paras 24 to 28. [186] Guindon at para 60. [187] Guindon at paragraph 60. ...
Old website (cra-arc.gc.ca)

Information for entities holding accounts with Canadian financial institutions

Tax Convention and the Standard for Automatic Exchange of Financial Account Information in Tax Matters, respectively. ... Tax Convention to determine if it can certify that it is not a specified U.S. person. ... Tax Convention, respectively. Also, see the following: Guidance on the Canada-U.S. ...
Current CRA website

Information for entities holding accounts with Canadian financial institutions

Tax Convention and the Standard for Automatic Exchange of Financial Account Information in Tax Matters, respectively. ... Tax Convention to determine if it can certify that it is not a specified U.S. person. ... Tax Convention, respectively. Also, see the following: Guidance on the Canada-U.S. ...
SCC

Vancouver Society of Immigrant and Visible Minority Women v. M.N.R., 99 DTC 5034, [1999] 1 SCR 10, [1999] 2 CTC 1

The counselling provided by the Society assists immigrant women in learning the social conventions and practical realities of a job interview, résumé preparation, applying for employment, and the like.  ...
TCC

Blackmore v. The Queen, 2013 DTC 1213 [at at 1147], 2013 TCC 264, aff'd 2014 DTC 5123 [at 7316], 2014 FCA 210

In those cases, the phrase “beneficial owner” was referenced as it appeared in a particular tax convention. ...

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