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-G. for Ontario (Labour Conventions Case) 96. Chief Justice Duff commented upon the carefully guarded language of Lord Watson and reviewed the Board of Commerce Case, supra, and Toronto Electric Commissioners v. ...

ON APPEAL FROM THE FEDERAL COURT OF APPEAL Taxation—Income tax—Exemption—American citizen carrying out a contract in Canada —Canada-United States of America Tax Convention, Article VIIIA—Applicability. ... The exemption is claimed under Article VIIIA of the Canada-United States of America Tax Convention, which, by statute, has the force of law in Canada. ...

XI (1) of the Convention) but in respect of its industrial and commercial profits attributable to its activity in the United States and determined in accordance with Art. I of the Convention. Industrial and commercial profits do not include interest. ... Reciprocal Tax Convention in respect of income derived from sources in the United States and that this withholding tax is a tax on income not profits. ...

The 1958 Geneva Convention was drafted so as to do no more than was necessary to achieve this result. Thus the Convention does not grant “sovereignty” over the continental shelf but rather “sovereign rights to explore and exploit”. ... Furthermore, several of the early State claims exceeded that which international law subsequently recognized in the 1958 Geneva Convention. ...

Je crois devoir ajouter que lorsque l’appelant a négocié simultanément la vente de l’immeuble et de ses actions dans la compagnie sa convention avec l’acquéreur de l’entreprise comportait la stipulation suivante: 2. ... Vu cette stipulation, il ne me paraît pas qu’il y ait lieu d’attacher beaucoup d’importance au fait que l’acte de vente de l’immeuble signé en exécution de cette convention comporte suivant la formule habituelle la cession de l’immeuble ‘‘avec bâtisses dessus érigées... et toutes dépendances y attachées’’. Rien n’indique qu’on ait entendu exécuter la convention d’achat de l’immeuble et des actions autrement qu’elle avait été originairement conclue. ...

The exemption is claimed under Article VIIIA of the Canada-United States of America Tax Convention, which, by statute, has the force of law in Canada. ...

Reciprocal Tax Convention prevented the application of the Income Tax Act in the way above outlined and that the Minister could not deny the taxpayer the full deduction of foreign taxes paid. Article XV of the Convention provides: 1. As far as may be in accordance with the provisions of the Income Tax Act, Canada agrees to allow as a deduction from the Dominion income and excess profits taxes on any income which was derived from sources within the United States of America and was there taxed, the appropriate amount of such taxes paid to the United States of America. 2. ...

Tax Convention provides: Notwithstanding the provisions of Articles III and IV, profits which a resident of one of the territories derives from operating ships or aircraft shall be exempt from tax in the other territory. ... That neither Section 10(1) (c) of the Income Tax Act nor Article V of the Tax Convention exempts earnings of the appellant from managing or agency or stevedoring services which it renders in Canada to other corporations: 2. ... Tax Convention, I do not rely upon the translation of the Convention, which appears as a Schedule to the French text of the Statutes of Canada 1946, c. 38. ...

The company claimed a refund of this latter amount from Nova Scotia on the theory that the provisions of the Canada-United States of America Tax Convention Act, 1944-45 (Can.), c. 31, was applicable. ... Act, but in the present case, no such question arises for the convention by its terms deals only with ‘the tax imposed under the Dominion Suc- cession Duty Act 9. ... The convention does not purport to affect any provincial power.’’ But with due deference, I cannot agree with the Court below on the second point. ...

International Copyright and Neighbouring Rights:  The Berne Convention and Beyond, vol.  ... WIPO Intellectual Property Handbook:  Policy, Law and Use, chapter 5, “International Treaties and Conventions on Intellectual Property”, No. 489, 2nd ed.  ... Ginsburg, International Copyright and Neighbouring Rights: The Berne Convention and Beyond (2nd ed. 2006), vol. ...