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The parties also agree that in 2003, HWEI and LF Luxembourg (collectively, the “Luxcos”) were resident in Luxembourg for the purposes of the Canada–Luxembourg Income Tax Convention (the “ Luxembourg Treaty ”). ... The carve-out for treaty-protected property in paragraph 115(1)(b) of the Act simply reflects what Canada had agreed to do under the Luxembourg Convention, i.e. to not tax the gain realized on the dispositions of certain properties. Therefore, in my view, the proper focus for the GAAR analysis, in this case, is on the provisions of the Luxembourg Convention. ...

Treaties and Other International Instruments Convention for the Protection of Human Rights and Fundamental Freedoms, 213 U.N.T.S. 221 [the European Convention on Human Rights], art. 7. ... Indeed, s. 11(i) has been characterized as the constitutional entrenchment of s. 44   (e) of the Interpretation Act   (Chevrette, Cyr and Tanguay‑Renaud, at pp. 780‑81; see also the comments of L’Heureux‑Dubé J. in Dunn, at paras. 49‑50, although dissenting, she was not contradicted by the majority). [75]                          The second provision which can be credited for inspiring the first draft of s. 11(i) is art. 7(1) of the European Convention on Human Rights, 213 U.N.T.S. 221 (“ ECHR ”), which came into force on September 3, 1953. ...

The Convention does not define the words "salaries, wages and other similar remuneration”. ... 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. ... 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 that 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. 4 Article 7(1) of the Convention reads as follows: Article 7 Business profits 1. ...

Tax Convention Act, 1984 (the “Tax Convention Act’, S.C. 1984, c. 20), when read with the Convention, for the legal compulsion of information or production of documents sought by the U.S. ... As indicated above, the Convention was incorporated into Canada's domestic law by virtue of the Tax Convention Act. ... Section 3 of the Tax Convention Act clearly states that the Convention has the force of law in Canada. ...

Counsel submitted Article III of the Tax Convention states that any term not defined in the Convention has the meaning it has under the law of the taxing state. ... Paragraph 9 of Article XIII of the Convention, for the purposes of this appeal, reads: 9. ... Judge Couture then reviews the law on the interpretation of international conventions. ...

The alternative position, of course, is that these were conventions, and they should be allowed at a maximum of two per year.... the out-of-Canada conventions.... ... M.N.R., [1985] 2 C.T.C. 2176; 85 D.T.C. 509] case regarding the Hawaii, the San Diego, and the Phoenix conventions, conventions or travelling expenses. ... The actual business, or the profits that the Appellants say are related to the conventions would only be incidental to the conventions. ...

Tax Convention (S.C. 7 George VI c. 21 as amended by 14 George VI c. 27). ... The sentence of the Convention relied upon by the appellant was added in 1950 (see S.C. 14 George VI c. 27). It must be read in context and conformably to the purpose and intent of the Convention as a whole. ...

The material provisions of the Act implementing the Convention are sections 2 and 3. 2. ... The guarantee fees paid to the plaintiff are not interest within the terms of the Canada-US Tax Convention. Paragraph 214(15)(a) of the Income Tax Act deeming them to be interest is inconsistent with the Convention and, by virtue of section 3 of the Act that makes the Convention part of Canada’s domestic law, paragraph 214(15)(a) cannot apply to guarantee fees subject to the 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 circum stances 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, plan ning, conducting, and evaluating annual teachers’ conventions for its members. ...

XIII (9) of the Canada-United States Income Tax Convention ("the Convention"). ... The question is which is the correct date under the Convention. The relevant part of the Convention is as follows:          Art. ... III (2) of the Convention and s. 3 of the Income Tax Conventions Interpretation Act clearly state that when a term is not defined in the Convention, as "gain" is not, it should be given "the meaning it has in the tax legislation of the taxing state. ...