Rodrigue v. Canada (Attorney Général), 2001 DTC 5296, 2001 FCA 157 -- summary under Article 18

In rejecting a submission of the taxpayer that he was entitled to a deduction for a contribution to a pension plan in the United States that was not registered by the Minister of National Revenue, the Court found (at p. 5297) that the phrase "income accrued" in paragraph 7 of Article XVIII of the Canada-U.S. Convention were "clearly meant to exempt only income earned on money in the plan, not contributions of capital made into the Plan." In any event, paragraph 7 had not come into force with respect to the taxation year in which the contribution was made.