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Treasury Department, approved by the Government of Canada, is an official guide to the Convention and reflects policies behind particular Convention provisions, as well as understandings reached with respect to the interpretation and application of the Convention. ... 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. 1984, c. 48, section 3. ... 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. ...

I dispute your decision that the convention was not within the territorial scope of the sponsoring organization. ... But his argument that this was a “convention”, while not accepted by the Minister, has not been successfully overturned by the Minister, and the facts are in support of it being termed just that — a “convention”, not “travelling”. ... A convention, yes, but probably more of a “self-help” or “personal motivation” conference than a regular business 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 circumstances 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, planning, conducting, and evaluating annual teachers" conventions for its members. ...

Which agreement or convention applies in the present case? 4.03.4 The 1980 Canada-United Kingdom Tax Convention was passed on December 17, 1980, and was declared to have force of law in Canada. ... In this provision, “the existing Agreement” means the 1966 Canada-United Kingdom Income Tax Agreement, and “this Convention” means the 1980 Canada-United Kingdom Income Tax Convention. ... Reference to article 6(3) of the Convention to “profits from the alienation of property” is a new feature of the Convention. ...

The Tax Treaty came into force on November 27, 1986 and was based on the Organization for Economic Cooperation and Development (“OECD”) Model Tax Convention on Income and on Capital 1977 (“Model Convention”). ...   [10]            The worldwide recognition of the provisions of the Model Convention and their incorporation into a majority of bilateral conventions have made the Commentaries on the provisions of the OECD Model a widely-accepted guide to the interpretation and application of the provisions of existing bilateral conventions (see Crown Forest Industries Ltd. v. Canada, [1995]     2 S.C.R. 802; Klaus Vogel, “ Klaus Vogel on Double Taxation Conventions ” 3rd ed. ...

However, the appellant contends, and all his attacks against the judgment of the Trial Division rest on that contention, that the new section 48 cannot be invoked against him in this case because there is an inconsistency between the operation of the new section 48 and article VIII of the Canada-United States Tax Convention (see The Canada-United States of America Tax Convention Act, 1943, Statutes of Canada 1943, c 21, section 3). ... Under the Convention a person, who, like the appellant, has become a resident of the United States, is not taxable in Canada by reason of the capital gains made by him after becoming a United States resident. ... In effect, the appellant’s contention that there was conflict between the Convention and the new section 48 was based on the view that the new section affected vested rights that the appellant had acquired under the old section 48 and the Convention. ...

Section 3 of the Canada-United States Tax Convention Act, 1943, S of C, c. 21 reads as follows: In the event of any inconsistency between the provisions of this Act or of the said Convention and Protocol and the operation of any other law, the provisions of this Act and of the Convention and Protocol shall, to the extent of such inconsistency, prevail. ... There are 26 concluded and 10 proposed tax conventions, treaties or agreements between Canada and other nations of the world. ... 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. ...

CONVENTION FOR THE AVOIDANCE OF DOUBLE TAXATION BETWEEN CANADA AND THE UNITED STATES OF AMERICA EDITORIAL NOTE: The following convention together with its protocol between Canada and the United States of America was signed at Washington on March 4, 1942 by Mr. ... ARTICLE XXII This Convention and the accompanying protocol which shall be considered to be an integral part of the Convention shall be ratified and the instruments of ratification shall be exchanged at Washington as soon as possible. This Convention and protocol shall become effective on the first day of January 1941. ...

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. ...