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Where any greater relief from tax would have been afforded by any provision of the 1942 Convention than under this convention, any such provision shall continue to have effect for the first taxable year with respect to which the provisions of this Convention have effect under paragraph 2(b). ... The OECD also publishes Commentaries on provisions of the OECD Convention. ... The introduction to the Commentary stated that the Committee “considered that existing conventions should, as far as possible, be interpreted in the spirit of the revised Commentaries, even though the provisions of these conventions did not include the more precise wording of the 1977 Model Convention”. ...

Exclusion par application de la Convention sur les réfugiés Exclusion — Refugee Convention 98 La personne visée aux sections E ou F de l’article premier de la Convention sur les réfugiés ne peut avoir la qualité de réfugié ni de personne à protéger. 98 A person referred to in section E or F of Article 1 of the Refugee Convention is not a Convention refugee or a person in need of protection. Irrecevabilité Ineligibility 101 (1) La demande est irrecevable dans les cas suivants : 101 (1) A claim is ineligible to be referred to the Refugee Protection Division if […] … d) reconnaissance de la qualité de réfugié par un pays vers lequel il peut être renvoyé; (d) the claimant has been recognized as a Convention refugee by a country other than Canada and can be sent or returned to that country; Convention des Nations Unies relatives au statut des réfugiés United Nations Convention Relating to the Status of Refugees Article premier.- Définition du terme "réfugié" Article 1- Definition of the term "refugee" E. ... This Convention shall not apply to a person who is recognized by the competent authorities of the country in which he has taken residence as having the rights and obligations which are attached to the possession of the nationality of that country. ...

Tax Convention (the "convention"), he is entitled to a complete exemption from taxation in Canada of his U.S. source pension income. ... The respondent further points out that attached to the convention is such an instrument referred to in paragraph 2(b), being the Technical Explanation of the the Canada—U.S. Convention (the “technical explanation”) of article XVIII of the convention together with an example. ...

They also were required to attend and participate in meetings, seminars, conventions, and promotional events in various locations, including in the United States. ... Nickerson is entitled to deduct: $3,729 for the bus hired to transport their team to a “major convention” in Ottawa; [7] $368.80 for attendance at a “major convention” in Massachusetts for which he was a speaker; [8] and $274.64 for a corn maze promotional event. [9] [22] The Respondent argues that some of the above convention expenses should not be allowed because subsection 20(10) of the Income Tax Act limits business expense claims to two conventions in a taxation year. While the Respondent relied on a compelling authority this regard, [10] I was not provided with evidence outlining the two conventions for which expenses had already been allowed for each taxation year. ...

On March 4, 1942, a Convention and Protocol was agreed upon by the two countries. ... The Convention entered into between Canada and the United States of America, set out in Schedule A, is approved and declared to have the force of law in Canada, and shall be deemed to be included in and to form part of the Convention and Protocol set out in the Schedule to The Canada-United States of America Tax Convention Act, 1943. ... On my reading of the Tax Convention, I should have also reached the conclusion that the denial of the foreign tax deduction for the earlier years as authorized by Section 38(1) of the Act also offended Article XV (1) of the Convention. ...

Tax Convention then in effect. He pointed out that under section 3 of the Canada-United States of America Tax Convention Act, 1943, the provisions of the convention and protocol between Canada and the United States must to prevail in the event of inconsistency between such provisions and those contained in the Income Tax Act. ... Tax Convention exempted the payment to Mr. Wood from the tax assessed. ... Convention cannot be reduced by reason of any amendment to the Income Tax Act made subsequent to the enactment of the Canada-United States Tax Convention Act, 1943, and in particular section 3 thereof. ...

First, the Officer notes that the Applicant’s H&C application was rejected in November 2018, finding that she was a Convention refugee in Germany. ... The particular issue was whether the status of withholding of removal under United States law is equivalent to the status of Convention refugee within the meaning of the Convention Relating to the Status of Refugees,  28 July 1951, 189 UNTS 150 (entered into force 22 April 1954) [the Convention] and under s 101(1)(d) of IRPA. [18]   In my view, it is clear that Wangden does not speak to the standard of review applicable to the first and third issues. ... Did the Officer err in determining that the Applicant has been recognized as a Convention refugee in Germany? ...

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. ...

Analysis The Minister in assessing the appellant admitted that he was in business and allowed deductions (other than the trips under appeal) as follows: 1980- $19,629.78 1981- $27, 619.44 1982- $19,894.92 The only items denied were for travelling to the United States for meetings and conventions. ... The convention locations or the climatic conditions alone did not serve to disallow the deductions. ... As a Canadian taxpayer he must be restricted by the provisions of subsection 20(10) of the Income Tax Act which reads: (10) Convention expenses. ...

The primary issue is whether the Tax Court correctly determined that although the appellant was deemed to be a resident of the United Kingdom under the Canada-United Kingdom Tax Convention (1978) (Convention), the Minister could assess tax on the basis that the appellant was a resident of Canada for the purposes of the Act. [4]                The second issue is whether the Tax Court correctly determined that Article 27(2) of the Convention applied so as to permit the Minister to tax the appellant's non-United Kingdom income, not just the appellant's income that arose in Canada. [5]                In our view, Chief Justice Rip made no error in his interpretation of the Convention. ...