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The Decision held that the Applicant is not a Convention refugee or a person in need of protection pursuant to sections 96 and 97 of the Immigration and Refugee Protection Act, SC 2001, c 27 [IRPA]. [2]   As explained in greater detail below, this application is allowed, because I have found that the RPD breached principles of procedural fairness by making credibility findings related to the Applicant’s testimony at an earlier RPD hearing, without affording her an opportunity to address those specific credibility concerns at the hearing before the RPD giving rise to its Decision. ... A hearing tribunal has no obligation to point to aspects of the applicant’s evidence that it finds unconvincing where the onus is on the applicant to establish a well-founded fear of persecution for reasons related to Convention refugee grounds. ...

For written reasons dated August 24, 2018, the RPD found that the applicant was neither a Convention refugee nor a person in need of protection because he had failed to establish his identity.   ... On this basis, the member concluded that the applicant was neither a Convention refugee nor a person in need of protection.   ...

Overview [1]   The Applicants seek judicial review of a December 14, 2018 decision made by a member of the Refugee Appeal Division [RAD] of the Immigration and Refugee Board of Canada [the Decision], upholding the December 21, 2017 decision of a member of the Refugee Protection Division [RPD], finding that the Applicants were not Convention refugees or persons in need of protection within the meaning of sections 96 and 97(1), respectively, of the Immigration and Refugee Protection Act, SC 2001, c 27 [IRPA]. [2]   For the reasons that follow, I find that the Decision is reasonable and that this application for judicial review must be dismissed. ... After considering the RPD’s decision and the Applicants’ arguments on appeal, the RAD concluded that overall the decision was correct and that there was insufficient credible evidence that the Applicants were Convention refuges or persons in need of protection. ...

The Officer rejected the Applicants’ application for Canadian permanent resident visas as members of the Convention refugee abroad class [Decision]. ... As the Applicants have not been successful in challenging the reasonableness of that finding, it precludes the Applicants being eligible for Convention refugee status, and I cannot conclude that the Decision is unreasonable based on the Officer not having analysed the claimed risk of persecution due to the Applicants’ ethnicity and religious beliefs. [24]   Here, the Officer was unable to make a determination on inadmissibility. ...

Finally, case law and legal theory are also unanimous as to the fact that the parties are bound by the apparent convention as against third persons. ... It is in fact not at all surprising that the parties to a simulation do not consent to the apparent act intended to deceive third persons even though they have taken the trouble to create a hidden convention that will govern the parties. ...

Toutefois, si cette influence découle d’un contrat de concession, d’une licence, d’un bail, d’un contrat de commercialisation, d’approvisionnement ou de gestion ou d’une convention semblable — la société et l’entité dominante n’ayant entre elles aucun lien de dépendance — dont l’objet principal consiste à déterminer les liens qui unissent la société et l’entité dominante en ce qui concerne la façon de mener une entreprise exploitée par la société, celle-ci n’est pas considérée comme contrôlée, directement ou indirectement, de quelque manière que ce soit, par l’entité dominante du seul fait qu’une telle convention existe. ...

Income Tax Convention, applicable to 1980, residents of the United States are exempt from tax on disposition of Capital property in Canada. ... Counsel for the appellant submitted that if I decide the beneficiaries were the only persons to have a vested interest in the Lands at the time, Article VIII of the Canada-United States of America Income Tax Convention of 1943 ("Tax Treaty") exempts the beneficiaries from paying tax to Canada with respect to the gain on the sale of the Lands. ...

For the purposes of paragraph 127(10.1)(c) of the Act, a prescribed expenditure is (a) an expenditure of a current nature incurred by a taxpayer in respect of (i) the general administration or management of a business, including (A) an administrative salary or wages and related benefits in respect of a person whose duties are not wholly directed to the prosecution of scientific research, (B) a legal or accounting fee, (C) an amount described in any of paragraphs 20(1)(c) to (i) of the Act, (D) an entertainment expense, (E) an advertising or selling expense, (F) a convention expense, (G) a due or fee in respect of membership in a scientific or technical society or organization, and (H) a fine or penalty, or (ii) the maintenance and upkeep of premises, facilities or equipment to the extent that such expenditure is not attributable to the prosecution of scientific research, except any such expenditure incurred by a taxpayer who derives all or substantially all of his revenue from the prosecution of scientific research or the sale of rights in or arising out of scientific research carried on by him;... ... Reference to Schedule 1 of the respondent's reply establishes that Stro- motich included accounting and legal expenses, advertising and promotion, convention costs, interest expense and rent. ...

Les parties reconnaissent avoir exigé la rédaction en anglais de la présente Convention ainsi que de tous documents et avis qui pourront être exécutés ou donnés à la suite des présentes ou ayant un rapport direct ou indirect avec la présente Convention. 8. ...

I verily believe this infringement contravenes my rights, declaration, and other laws as follows: A) Charter of Rights B) The Canadian Bill of Rights C) The United Nations International Convention on the Elimination of all forms of Racism D) The Universal Declaration of Human Rights E) The International Covenant on Economic, Social and Cultural Rights F) The International Convention on the Elimination of all forms of Discrimination against Women G) The United Nations Declaration on the Rights of “A Child”- 1991 H) Canada Action Plan for Children I) Campaign 2000 J) Child Development Initiative (1990)- Brighter Futures K) Twentieth Century Rights- as per Constitution L) International Year of the Family (1994) United Nations M) International Year for the Eradication of Poverty (1996) United Nations N) And any other reasons, laws, declaration the Appellant may formulate O) These are not facts, as so the Respondent states-these are laws ratified by Canada, and therefore law, and can not be denied. 17. ...