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Yao was not a Convention refugee or a person in need of protection. b) Ms. ... Zhang’s children were Convention refugees. [43] This meant that refugee protection was conferred on them and they became protected persons within the meaning of the IRPA. ... Conferral of refugee protection 95 (1) Refugee protection is conferred on a person when (a) the person has been determined to be a Convention refugee or a person in similar circumstances under a visa application and becomes a permanent resident under the visa or a temporary resident under a temporary resident permit for protection reasons; (b) the Board determines the person to be a Convention refugee or a person in need of protection; or (c) except in the case of a person described in subsection 112(3), the Minister allows an application for protection. [53] This list is exhaustive and is not open and flexible. ...

  [1]               The issue in this Appeal is whether the Appellant is entitled, in determining its tax payable for 2003 under the Income Tax Act (the “ Act ”), to a foreign tax credit in the amount of $3,199,601 either pursuant to subsection 126(2) of the Act or paragraph 2 of Article XXIV of the Canada- United States Tax Convention. ... Since I have determined that the Appellant is entitled to claim this credit pursuant to subsection 126(2) of the Act, and since the arguments related to the Canada – United States Tax Convention were raised as alternative arguments if the Appellant was not entitled to the foreign tax credit pursuant to subsection 126(2) of the Act it is not necessary to consider the arguments related to the Convention and these will not be addressed ...

European Convention for the Protection of Human Rights and Fundamental Freedoms, 213 U.N.T.S. 222, Art. 5(3).   ... Article 5(3) of the European Convention for the Protection of Human Rights and Fundamental Freedoms, 213 U.N.T.S. 222, provides, in the English version, that "everyone arrested or detained... shall be entitled to trial within a reasonable time or to release pending trial". Like the Charter  , the French version of the convention expresses this right by means of the word " jugée ", which in Wemhoff the European Court interpreted as referring to the termination of the trial. ...

OECD CONVENTION AND COMMENTARY   [59]      Subsection 69(2) of the Act is analogous to Article 9(1) of the OECD Model Double Taxation Convention on Income and Capital. ... This amount is reduced to ten percent under Article 10(1)(a) of the Canada-United Kingdom Tax Convention(1978). ...

But the King never had any rights against you but to such parts of the Country as had been fairly ceded by yourselves with our own free consent by Public convention and sale. ... Under the Vienna Convention on the Law of Treaties, a third party being referred to is a third State. Article 34 of the Convention reads:      A treaty does not create either obligations or rights for a third State without its consent.               ...

The Convention, annexed as a schedule to the above Act, discloses that among the taxes which are the subject of the Convention are Canadian income taxes. Article ll(2) provides that: In the application of the provisions of this Convention by one of the contracting States any term not otherwise defined in this Convention shall, unless the context otherwise requires, have the meaning which it has under the laws in force in the territory of that State relating to the taxes which are the subject of this Convention. ... That being so, there being no definition of “interest” in the Convention, by virtue of Article 11(2), supra, the term for the purposes of the Convention must have the meaning attributable to it in Canada. ...

The question at issue is whether the appellant's income is exempted from taxation in Canada by virtue of Article 14 of the Canada-United Kingdom Income Tax Convention, 1980, S.C. 1980-81-82-83, c. 44, part X (the "Convention"), and whether Article 15 of this Convention is applicable. Article 14 and the pertinent part of Article 15 of the said Convention read as follows: Article 14 1. ... With regards to Article 14 of the Convention, the Commentary says in part the following: 1. ...

Treasury Department, approved by the Government of Canada, is an official guide to the Convention and reflects policies behind particular Convention provisions, as well as understandings reached with respect to the interpretation and application of the Convention. ... Notwithstanding the provisions of a convention or the Act giving the convention the force of law in Canada, it is hereby declared that the law of Canada is that, to the extent that a term in the convention is (a) not defined in the convention, (b) not fully defined in the convention, or (c) to be defined by reference to the laws of Canada, that term has, except to the extent that the context otherwise requires, the meaning it has for the purposes of the Income Tax Act, as amended from time to time, and not the meaning it had for the purposes of the Income Tax Act on the date the convention was entered into or given the force of law in Canada if, after that date, its meaning for the purposes of the Income Tax Act has changed. 1984, c. 48, section 3. ... This fact is indicated in the preamble to the Convention. Accordingly, it is undesirable to look beyond the four corners of the Convention and Protocol when seeking to ascertain the exact meaning of a particular phrase or word therein. ...

I dispute your decision that the convention was not within the territorial scope of the sponsoring organization. ... But his argument that this was a “convention”, while not accepted by the Minister, has not been successfully overturned by the Minister, and the facts are in support of it being termed just that — a “convention”, not “travelling”. ... A convention, yes, but probably more of a “self-help” or “personal motivation” conference than a regular business convention. ...

P-3] read: Teachers" conventions 105 (1) The Association, through its convention associations, may plan, organize or authorize annual teachers" conventions to be held on teaching days. (2) The object of the teachers" conventions shall be to maintain and improve the knowledge, skill and competence of teachers. 106 Except as otherwise approved by a convention association pursuant to Bylaw 108, all active members shall attend the annual teachers" convention of the local association as planned, organized or authorized by its convention association. 107 The duties, organization and operation of each convention association shall be as set out in the standard constitution for convention associations, which shall be subject to modifications approved by the Provincial Executive Council. 108 A convention association, through its convention board, may in special circumstances grant permission to active members of the Association to attend alternate professional development activities rather than their annual teachers" convention. ... P-1]: ATTENDANCE AT CONVENTION Teachers have a legal as well as a professional obligation to attend their annual teachers" convention. ... The ATA, through convention associations, has the responsibility for authorizing, planning, conducting, and evaluating annual teachers" conventions for its members. ...