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The evidence indicated that the person entitled to vote at a leadership convention fall into two categories. ... Policies passed in convention do not bind him. He cannot be fired, except folowing a leadership review at a convention, a process which the appellant described as analogous to impeachment. ...

Définitions       « convention unanime des actionnaires » “unanimous shareholder agreement” « convention unanime des actionnaires » Convention visée au paragraphe 146(1) ou déclaration d’un actionnaire visée au paragraphe 146(2).     145.1 Des actionnaires peuvent conclure entre eux une convention écrite régissant l’exercice de leur droit de vote.     146. (1) Est valide, si elle est par ailleurs licite, la convention écrite conclue par tous les actionnaires d’une société soit entre eux, soit avec des tiers, qui restreint, en tout ou en partie, les pouvoirs des administrateurs de gérer les activités commerciales et les affaires internes de la société ou d’en surveiller la gestion ...   (3) L’acquéreur ou le cessionnaire des actions assujetties à une convention unanime des actionnaires est réputé être partie à celle-ci ...     (6) Il est entendu que le présent article n’empêche pas les actionnaires de lier à l’avance leur discrétion lorsqu’ils exercent les pouvoirs des administrateurs aux termes d’une convention unanime des actionnaires.   ...

In addition to disputing liability under the aforementioned sections of the Statute defendant relies on Articles I and II of the Canada-US Tax Convention and Clause 6(a) of the Protocol thereto and the Canada-United States of America Tax Convention Act, 1943-44 S of C c 21. ... Subject to the provisions of this Convention such items of income shall be taxed separately or together with industrial and commercial profits in accordance with the laws of the contracting States. and clause 6(a) of the Protocol defines the term “rental and royalties’’ referred to in Article Il of the Convention in the following manner: The term “rental and royalties” referred to in Article II of this Convention shall include rentals or royalties arising from leasing real or immovable, or personal or movable property or from any interest in such property, including rentals or royalties for the use of, or for the privilege of using, patents, copyrights, secret processes and formulae, goodwill, trade marks, trade brands, franchises and other like property. ... I also conclude therefore that under the provisions of the Canada- US Tax Convention the payments made were not subject to the deduction of withholding tax as required by subsection 215(6) of the Act. ...

The Treaty is generally patterned on the 1977 Model Double Taxation Convention prepared by the Organisation for Economic Co-operation and Development (the "OECD") (the "OECD Model Convention"). ...   [22]     This issue appears to have been addressed by the 2002 Update to the OECD Model Tax Convention:   Thus, whilst some countries have felt it useful to expressly clarify, in their conventions, that controlled foreign companies legislation did not conflict with the Convention, such clarification is not necessary. It is recognised that controlled foreign companies legislation structured in this way is not contrary to the provisions of the Convention.   ...

Income Tax Convention (1980) (hereinafter the "Treaty") he was a resident of the U.S. by virtue of the tie-breaker rule. ...   [29]     In Canada, section 3 of the Income Tax Conventions Interpretation Act, R.S., 1985, c. I‑4, provides further direction in this regard:   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 ...

Aloysious would not face more than a mere possibility of risk under any of the Convention grounds as set out in section 96 of the Act. ... Aloysious would not face “more than a mere possibility of risk under any of the Convention grounds”. ... The concluding paragraph of the reasons, as noted in paragraph 4 above, demonstrates that the Officer was aware of, and applied the correct legal test, as it relates to s. 96 – namely, whether there is more than a mere possibility of persecution on a Convention ground. ...

For these reasons, the panel will grant you the benefit of the doubt and recognize you as a "convention refugee" and a "person in need of protection". ... However, as it is today your wedding anniversary and that the panel has no intention of separating what love has united, I will also grant you the benefit of the doubt and recognize you as a "convention refugee" and a "person in need of protection". ... After reviewing section 181 and following of the Handbook on Procedure and Criteria for Determination of Refugee Status, this Court held that the definition of Convention refugee to which Canada subscribes by virtue of it being a signatory of the United Nation Convention Relating to the Status of Refugees (Geneva, July 28, 1951) does not incorporate the concept of family unity. ...

Income Tax Convention, the tax on such income is either 10% or 15%. Because of that Tax Convention, the statutory rate of 25% in section 212 no longer applies. ... The Tax Convention reduces the rate to 10% or 15% and, as the Appellant's son acknowledged when he testified in this appeal, she does not dispute the amounts of tax or interest. ... Under the provisions of the Canada/US Tax Convention, a taxpayer may make an application to a "competent authority" to obtain relief from double taxation where it exists. ...

The law in Canada and in the United States had been different and not clearly settled and this convention was for the purpose of making a simple rule. Notwithstanding the supplementary argument of counsel for the administrator, I am of opinion that this convention can have no application to a question of situs arising under the Nova Scotia Succession Duty Act. ... 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 Succession Duty Act f ’. ...

On October 12, 2016, the RPD rendered a decision denying the Applicant’s refugee claim on the basis that he is excluded under section 98 of the IRPA and Article 1F(a) of the Refugee Convention.   ... Relevant Provision [25]   Section 98 of the IRPA reads as follows: Exclusion — Refugee Convention 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. Exclusion par application de la Convention sur les réfugiés 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. [26]   Pursuant to section 98 of the IRPA, Article 1F(a) of the Refugee Convention excludes individuals from refugee protection when there are serious reasons for considering that they have committed crimes against peace, a war crime, or a crime against humanity.   ...