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Under subsection 3(2) of the Convention Act, provisions of the convention prevail over provisions of the Act where there is an inconsistency. ... The convention was ratified and entered into force on August 16, 1984. ... Under subsection 3(2) of the convention Act, the convention prevails over the Act in the event of an inconsistency. ...

The court concluded that those meetings were conventions within the meaning of the Act. ... A convention does not become a training course when some of its sessions take the form of workshops. It is a question of fact whether a "seminar" is a convention or a training course. ...

This convention was advertised in the United States and Europe as well as in Canada. ... If the very raison d'être of the entity which holds a convention is to organize and stage conventions inside and outside of Canada for profit then I believe that its territorial scope, for the purposes of subsection 20(10), is where it in fact holds conventions. ... The nature of the convention site and its climatic attractions are also relevant. ...

The "Mutual Agreement Procedure" article in conventions entered into by Canada entitles the Canadian taxpayer to request competent authority assistance when action(s) of either government results in double taxation or taxation not in accordance with the convention. 3. ... Although in most cases the competent authorities reach agreement and relieve double taxation or taxation not in accordance with the convention, there is no appeal procedure under the tax conventions for dealing with cases when agreement cannot be reached. ... Paragraph 2 of the Protocol to the Canada-Japan Convention reads as follows: 2. ...

The “Mutual Agreement Procedure” article in conventions entered into by Canada entitles the Canadian taxpayer to request competent authority assistance when action(s) of either government results in double taxation or taxation not in accordance with the convention. 3. ... Although in most cases the competent authorities reach agreement and relieve double taxation or taxation not in accordance with the convention, there is no appeal procedure under the tax conventions for dealing with cases when agreement cannot be reached. ... Paragraph 2 of the Protocol to the Canada-Japan Convention reads as follows: 2. ...

(b) Canada-Israel Income Tax Convention Article XXIII (1)(a), (2)(b), (c) Article XXIII. ... 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. ... Such interpretation, he said, is not in conformity with a liberal interpretation of the convention. ...

With respect to the tax conventions, he argued that the Finland convention provides at article 3 that if there is an inconsistency between the Act and the convention, it is the convention that must prevail, that Finland does not have to pay tax unless it has a permanent establishment in Canada, adding that the same provision existed in all the other conventions. ... (Organization for Economic Co-operation and Development) 1963 Draft Convention: In its brief analysis of the Articles of the Draft Convention, the O.E.C.D. ... Model Convention states that: Contracting States are free to omit this sentence and treat penalty charges as interest in their bilateral conventions. ...

The Minister had allowed the deductions for two conventions in each of those two years. ... Amway apparently had one convention per year which the appellant did not attend. ... Were the expenditures "convention" expenses under subsection 20(10) of the Act? ...

Conventions of this sort are typically attended by a large number of GM head office personnel, including several of the most senior executives. ... The Appellant, quite understandably, viewed this request as an invitation he could not refuse, and he and his wife therefore attended and took part in the convention. [6] The evidence before me as to the exact nature of the agenda for this convention was scant indeed. ... Here the predominant purpose of the Appellant’s attendance at the convention, and that of his wife, was to further the employer’s business. ...

Conventions of this sort are typically attended by a large number of GM head office personnel, including several of the most senior executives. ... The evidence before me as to the exact nature of the agenda for this convention was scant indeed. ... Here the predominant purpose of the Appellant’s attendance at the convention, and that of his wife, was to further the employer’s business. ...