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Model Tax Convention on Income and Capital, the U.N. Model Conventions, as well as academic articles and textbooks. [14]     Articles 31 and 32 of the Vienna Convention on The Law of Treaties to which Canada acceded in 1970 and which came into force in 1980 also sets out principles applicable to treaty interpretation. ... Model Convention on which the Canada-U.S. Convention was based in part appears to support that domestically-employed government workers are not what the drafters had in mind with regard to the scope of Article XIX. ... Model Convention is almost identical to Article XIX under the Canada-U.S. ...

Here, I will simply provide a general description of some essential elements. [6] Since 1975, Canada and France have been parties to the Convention that is based on the Organization for Economic Co-operation and Development (OECD) Model Tax Convention on Income and on Capital. ... Article 26 of the Convention provides that the competent authorities of the Contracting States shall exchange information that is foreseeably relevant for carrying out the provisions of the Convention. ... The judge interpreted the Convention correctly, and the appellant did not persuade me that, if applicable, any potential assessment by France would run counter to the Convention. [53] For all these reasons, I would dismiss the appeal with costs. ...

This process involves looking to the language used and the intentions of the parties. [10]         This pronouncement echoes the general rule for the interpretation of a treaty, found in Article 31(1) of the Vienna Convention on the Law of Treaties [3] (the “ Vienna Convention ”), to which Canada is a signatory. ... 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 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. [12]         Similar to section 3 of the ITCIA, Article III(2) of the Treaty provides that: 2. As regards the application of this Convention by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject to this Convention. ...

T.S. 2010 No. 3) (Bunkers Convention), which is one of the ten articles of the Bunkers Convention that were given force of law in Canada by section 69 of the MLA. Articles 1 to 10 of the Bunkers Convention are included at Schedule 8 of the MLA. ... Time from which interest accrues (2) Interest accrues on a claim under this Part (a) if the claim is based on paragraph 77(1)(a) or on Article III of the Civil Liability Convention or Article 3 of the Bunkers Convention, from the day on which the oil pollution damage occurs; (b) if the claim is based on section 51 or 71 or paragraph 77(1)(b) or (c), or on Article III of the Civil Liability Convention or Article 3 of the Bunkers Convention as they pertain to preventive measures, (i) in the case of costs and expenses, from the day on which they are incurred, or (ii) in the case of loss or damage, from the day on which the loss or damage occurs; or (c) if the claim is based on section 107, from the time when the loss of income occurs. ...