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Counsel submitted Article III of the Tax Convention states that any term not defined in the Convention has the meaning it has under the law of the taxing state. ... Paragraph 9 of Article XIII of the Convention, for the purposes of this appeal, reads: 9. ... Judge Couture then reviews the law on the interpretation of international conventions. ...

The alternative position, of course, is that these were conventions, and they should be allowed at a maximum of two per year.... the out-of-Canada conventions.... ... M.N.R., [1985] 2 C.T.C. 2176; 85 D.T.C. 509] case regarding the Hawaii, the San Diego, and the Phoenix conventions, conventions or travelling expenses. ... The actual business, or the profits that the Appellants say are related to the conventions would only be incidental to the conventions. ...

Tax Convention (S.C. 7 George VI c. 21 as amended by 14 George VI c. 27). ... The sentence of the Convention relied upon by the appellant was added in 1950 (see S.C. 14 George VI c. 27). It must be read in context and conformably to the purpose and intent of the Convention as a whole. ...

The material provisions of the Act implementing the Convention are sections 2 and 3. 2. ... The guarantee fees paid to the plaintiff are not interest within the terms of the Canada-US Tax Convention. Paragraph 214(15)(a) of the Income Tax Act deeming them to be interest is inconsistent with the Convention and, by virtue of section 3 of the Act that makes the Convention part of Canada’s domestic law, paragraph 214(15)(a) cannot apply to guarantee fees subject to the Convention. ...

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. ...

XIII (9) of the Canada-United States Income Tax Convention ("the Convention"). ... The question is which is the correct date under the Convention. The relevant part of the Convention is as follows:          Art. ... III (2) of the Convention and s. 3 of the Income Tax Conventions Interpretation Act clearly state that when a term is not defined in the Convention, as "gain" is not, it should be given "the meaning it has in the tax legislation of the taxing state. ...

Question 2   No other provisions in the [Tax] Convention apply in this appeal because the premium for health insurance is not a tax within the meaning of the Convention. Article 2 states that the Convention applies only to levies that are “taxes” on income:   Article 2 [of the Tax Convention]   Taxes Covered   1.       ... Klaus Vogel et al., Klaus Vogel on Double Taxation Conventions, 3rd ed. ...

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. ...

Income Tax Convention, the appellant should be considered a resident of the United States and that the convention prevails over the Act. ... Income Tax Convention, as applicable for the taxation years at issue, which read as follows: CANADA-UNITED STATES TAX CONVENTION ACT, 1984 CONVENTION APPROVED 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. ... Income Tax Convention will dispose of the question of the appellant's residency. ...