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In addition, the Request Submissions explained why the Minister was not barred from doing so by the Canada-Cyprus Income Tax Convention (the “ Cyprus Convention ”). The Cyprus Convention is a bilateral treaty between Canada and Cyprus that stipulates a five-year limitation period for increasing the tax base of a resident of either contracting state, among other things. [24] On November 12, 2019, Mr. ... I therefore find the Minister relied on the Applicant’s failure to seek a Mutual Agreement Procedure under the Cyprus Convention in a manner that does not fetter its discretion under subsection 152(4) of the Act. ...

Nonis’ remedy, if any, lies to the south [33] The Canada-United States Tax Convention was entered into, inter alia, to prevent double taxation, fiscal avoidance and fiscal evasion. ... This is also how this Court and others have interpreted Article XXIV of the Canada-United States Tax Convention. [38] Accordingly, there is no basis under Canada-United States Tax Convention to allow the appeal by vacating the assessments. Canada was within its rights under the Canada-United States Tax Convention to assess tax on the amounts received by the Appellant from MLSE in 2015 and 2016. ...

Income Tax Convention (1978) (the " Convention "); and j)               none of the Pension Benefits received by the Appellant in 1998 from the CFA were exempt from income tax in Canada by virtue of a provision contained in the Convention. ... Income Tax Convention also provides inclusions for the word "pension". ... The Appellant is therefore subject to the Tax Convention. [21]          As has been noted in Merritt v. ...

Further, the CRA’s position ignores the fact that the Crown Forest decision states that tax conventions must be interpreted by reference to the purpose and intention of the parties to the convention. ... Tax Convention as to the non‑taxable entities included as a “resident”. ... Tax Convention.   2.  In the alternative, the taxpayer states that it understands that amendments to the Canada-US Tax Convention will be announced shortly and said amendments will provide treaty protection to LLC’s. ...

This is obvious from the text of Article 2 of the Convention and of the OECD Model. ... This is another indication that the Convention does not apply to the HKSAR. ... Baker, Double Taxation Conventions and International Tax Law, 2 nd ed. ...

Evidence was also provided about the Convention on International Civil Aviation, 7 December 1944, 15 UNTS 295 [Convention], including Annex 17 – Safeguarding International Civil Aviation Against Acts of Unlawful Interference [Annex 17]. [41] In Kiss at paragraph 23, the Court noted that Chapter 4.2 of Annex 17 of the Convention, titled Measures relating to access control, requires each contracting state to control access to secure areas at airports to prevent unauthorized entry. ... The evidence regarding training and the Convention appears in just three paragraphs of Kiss. ... This conclusion was only partially dependent on the evidence adduced by the AGC concerning the training of private security personnel or the implementation of Article 17 of the Convention. ...

United Nations Framework Convention on Climate Change, U.N. Doc. A/AC.237/18 (Part II)/Add.1, May 15, 1992, preamble. ... Framework Convention on Climate Change. Report of the Conference of the Parties on its twenty-first session, U.N. ... Attorney‑General for Ontario,  [1937] A.C. 326 (P.C.) (“ Labour Conventions ”), at pp. 351‑53). ...

It therefore found that the applicant was excluded under Article 1E of the Convention. ... Exclusion — Refugee Convention Exclusion par application de la Convention sur les réfugiés 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. 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. ... Indeed, section 98 of the IRPA clearly indicates that a person referred to in Article 1E of the Convention is excluded and is not a Convention refugee or a person in need of protection. ...

In that convention the phrase is defined as follows:   Article 2   1.         ... The Convention on Social Security between Canada and the Swiss Confederation came into force on October 1, 1995. It is my opinion that the phrase “social security legislation” has the same meaning in both the 1998 Convention and the Convention on Social Security between Canada and the Swiss Confederation. ...

Article 31 of the Vienna Convention on the Law of Treaties (1969) to which Canada subscribed governs the general rule of interpretation to be applied. ... That section reads: 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 Par dérogation à toute convention ou à la loi lui donnant effet au Canada, le droit au Canada est tel que les expressions appartenant aux catégories ci-dessous s'entendent, sauf indication contraire du contexte, au sens qu'elles ont pour l'application de la Loi de l'impôt sur le revenu compte tenu de ses modifications, et non au sens qu'elles avaient pour cette application à la date de la conclusion de la convention ou de sa prise d'effet au Canada si, depuis lors, leur sens pour la même application a changé. Les catégories en question sont: (a) not defined in the convention, a) les expressions non définies dans la convention; (b) not fully defined in the convention, or b) les expressions non définies exhaustivement dans la convention; (c) to be defined by reference to the laws of Canada, c) les expressions à définir d'après les lois fédérales. 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. ...