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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. ...

The Convention [7]                 Canada and the United States are parties to the Convention Between Canada and the United States of America with respect to Taxes on Income and on Capital, as amended by the Protocols signed June 14, 1983 and March 28, 1984 (the "Convention"). ... It could jeopardize working relations between Canada and the United States under the Convention. [19]            The second requirement of paragraph 13(1)(a) is that the information must have been obtained in confidence. [20]            All information exchanged under Article XXVII of the Convention relating to Article XXVIA of the Convention is treated as secret by both CCRA and the IRS. ... The information requested is about information exchanged under the Convention, and therefore, it should be treated in the same manner as information exchanged under the Convention. ...

The Convention, and two subsequent amending protocols are Schedule I and Schedules II and III referred to in and implemented by the Canada-United States Tax Convention Act, 1984, S.C. 1984, c. 20, 32-33 Elizabeth II. That statute provides: 3.(1) The Convention is approved and declared to have the force of law in Canada during such period as, by its terms, the Convention is in force. (2) In the event of any inconsistency between the provisions of this Act, or the Convention, and the provisions of any other law, the provisions of this Act and the Convention prevail to the extent of the inconsistency. ... Strict interpretation of tax conventions has been repudiated in The Queen v. ...

This application concerns a decision of the Refugee Appeal Division [RAD] dated November 7, 2018, confirming the decision of the Refugee Protection Division [RPD] dated December 19, 2017. [2]   This case raises issues with respect to section 98 of the IRPA, which incorporates Article 1E of the United Nations Convention Relating to the Status of Refugees [Convention]. ... Relevant provisions: section 98 of IRPA and Article 1(E) of the Convention [20]   The following provision of the Act is relevant in this case: 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. [21]   Furthermore, the following provision of the Convention states: Article 1- Definition of the term “ refugee ” Article 1.- Définition du terme « réfugié » E. ... First, they argue that they did not enjoy the same rights and obligations as Brazilian citizens and that the Convention therefore did not apply. ...

By way of background, I note that Canada is a signatory of the Convention Relating to the Status of Refugees (“Refugee Convention”). Article 1A of the Refugee Convention defines Convention refugees, and the definition has been incorporated into the law of Canada by way of s 96 of the IRPA. ... Interpretation of terms (1) Voluntary re-availment of national protection Article 1 C (1) of the 1951 Convention: “He has voluntarily re-availed himself of the protection of the country of his nationality;” 118. ...

The RPD did not find credible the allegations of persecution in Honduras and found that the Applicants were able to regain their residency status in Honduras, and as such were excluded under Article 1E of the Convention Relating to the Status of Refugees [Convention]. ... Exclusion on the basis of Article 1E of the Convention [20]   The Applicants first argue that the RPD erred in its assessment of their status in Honduras. ... Article 1E of the Convention and section 98 of the IRPA are meant to preclude “asylum shopping”, in situations where a person already enjoys protection from a third country (Zeng at para 1). ...

He seeks disclosure of certain statistical information from the Canada Revenue Agency (CRA) regarding collection assistance under paragraph 1 of Article XXVII relating to Article XXVI A of the Protocol amending the Convention Between Canada and the United States of America (the U.S.) with respect to Taxes on Income and on Capital (the Convention). ... The Convention and the amending Protocol were implemented respectively by the Canada-United States Tax Convention Act, 1984, S.C. 1984, c. 20 and the Act to Amend the Canada-United States Tax Convention Act, 1984, S.C. 1995, c. 34. ... The Convention provides for an arrangement for the collection of money from those not within the jurisdiction. ...

The Canada-US Tax Treaty has been approved by Parliament and has the force of law in Canada by the effect of the Canada-United States Tax Convention Act, 1984, SC 1984, c 20 [Tax Convention Act]. ... The competent authorities of the Contracting States shall exchange such information as may be relevant for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes to which this Convention applies insofar as the taxation thereunder is not contrary to this Convention. 1. Les autorités compétentes des États contractants échangent les renseignements pertinents à l'application des dispositions de la présente Convention ou à celles de la législation interne des États contractants relatives aux impôts auxquels s'applique la présente Convention dans la mesure où l'imposition qu'elle prévoit n'est pas contraire à la présente Convention.   […]   […] [Emphasis added.]   ...

Overview [1]   This Judgment relates to an application for judicial review of a decision dated December 17, 2018, by the Refugee Protection Division [RPD] of the Immigration and Refugee Board of Canada, which allowed an application brought by the Respondent Minister under s 108(2) of the Immigration and Refugee Protection Act, SC 2001, c 27 [IRPA] for cessation of the Applicant’s status as a Convention refugee [the Decision]. ... Decision Under Review [7]   In considering the Minister’s application for cessation, the RPD noted that s 108(1)(a) of IRPA is modelled on Article 1C(1) of the Convention Relating to the Status of Refugees, 189 UNTS 137 (adopted 28 July 1951, entered into force 22 April 1953) and the Protocol Relating to the Status of Refugees, 606 UNTS 267 (adopted 31 January 1967, entered into force 4 October 1967) [collectively, the Convention]. ... If the RPD’s reavailment and cessation decision is correct, is section 46(1)(c.1) of IRPA unconstitutional and inoperative because it results in the violation of the Applicant’s rights under sections 7, 12 and 15 of the Charter of Rights and Freedoms, in a manner which cannot be justified as a reasonable limit in a free and democratic society, the violation of the Applicant’s rights under sections 1(a) and (b), and 2(a), (b), and (e), of the Bill of Rights, and is also contrary to Canada’s obligations as a signatory of the Convention? ...

Section 3 of the Canada-France Income Tax Convention Act, 1951, reads as follows: 3. ... There is no definition of “pension” in the Canada-France Act or Convention. ... Also Parliament as a lexicographer of the word “pension” in the Convention adopted in the Canada-France Income Tax Convention Act, 1976 at Article XVIII prescribes that pensions may be “periodic or nonperiodic”. ...