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. ·          “twinning arrangement” « convention de jumelage » “twinning arrangement” means the pairing of two distinct film or video productions, one of which is a Canadian film or video production and the other of which is a foreign film or video production. ...

BACKGROUND [1]   In November 2015, the Canada Revenue Agency [CRA] commenced an audit of the personal tax returns of the Respondent for the 2006 to 2014 taxation years. [2]   The audit was triggered by information that the CRA received from French authorities under Article 26 of the Convention between Canada and France for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, Canada and France, 2 May 1975, Can TS 1976 No 30, as amended [Treaty]. [3]   The information relates to what is publicly known as the “Falciani List.” ...

In Suresh, this term, employed at section 19 of the former Act, which is the predecessor, of sorts, of section 34 of the Act, was defined as follows: 98     In our view, it may safely be concluded, following the International Convention for the Suppression of the Financing of Terrorism, that “terrorism” in s. 19 of the Act includes any “act intended to cause death or serious bodily injury to a civilian, or to any other person not taking an active part in the hostilities in a situation of armed conflict, when the purpose of such act, by its nature or context, is to intimidate a population, or to compel a government or an international organization to do or to abstain from doing any act”.  ...

The parents’ primary role regarding the upbringing of their children and the subsidiary role of the State with respect to youth protection are recognized in the Convention on the Rights of the Child, RT Can 1992 no 3, art 3, 5, 19 and 20; see also B (R) v Children’s Aid Society of Metropolitan Toronto, [1995] 1 SCR 315 at 370–371, and Winnipeg Child and Family Services v KLW, 2000 SCC 48 at paragraphs 72–80, [2000] 2 SCR 519. [14]   Each Canadian province and territory has enacted youth protection legislation. ...

In argument, the Applicant identified a wide range of international documents that were cited by different objectors; these included the Law of the Seas Treaty, the Convention on the Rights of Indigenous Peoples and the Principles and Objectives for Nuclear Non-Proliferation and Disarmament. ...

an order declaring that the Deputy Minister’s decision is discriminatory and contrary to the United Nations Convention on the Rights of Persons with Disabilities; 5.   ...

Chan that the proposed disposition of the shares by the PT would escape taxation in Canada because of the application of Article XIII(5)(a) of the Convention Between Canada and the United States of America with Respect to Taxes on Income and on Capital, September 26, 1980, Can. ...

T-777-23 concerns a different group whose information is being sought in relation to an Australian Tax Office request, pursuant to the Convention on Mutual Administrative Assistance in Tax Matters, 25 January 1988 (as amended on 27 May 2010), ETS 1988 No 127 (entered into force 1 June 2011, accession by Canada 21 November 2013). ...

The Respondents assert that they are US residents and take the position that, if the Minister wishes to obtain information from them for the purposes of administering and enforcing the Act, then she must follow the procedure set out in Article XXVII of the Canada-United States Convention with Respect to Taxes on Income and on Capital, 26 September 1980 (entered into force 16 August 1984) as amended [the US Treaty]. ...

Certain portions of the Canada-US Tax Convention and Protocol dated March 4, 1942 are also applicable as follows: CONVENTION Article I An enterprise of one of the contracting States is not subject to taxation by the other contracting State in respect of is industrial and commercial profits except in respect of such profits allocable in accordance with the Articles of this Convention to its permanent establishment in the latter State. ... 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. ... Unless the credit is allowed, therefore, there would be double taxation on this amount, contrary to the intention of the Tax Convention. ...