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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 competent authorities of the contracting states shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the contracting states concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention.... 2. ... In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a contracting state the obligation: (a) To carry out administrative measures at variance with the laws and administrative practice of that or of the other contracting state; (b) To supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other contracting state; or 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. (3) The Minister of National Revenue may make such regulations as are necessary for the purpose of carrying out the Convention or for giving effect to any of the provisions thereof. ... Attorney General of Canada, [1991] 2 C.T.C. 70, 91 D.T.C. 5424 (F.C.T.D.); [1992] 2 C.T.C. 356, 92 D.T.C. 6567 (F.C.A.), Joyal J. of this Court held that section 231.2 of the Income Tax Act, read with section 3 of the Convention Act and Article XXVII of the Convention, empowers the Minister to issue a requirement for the information sought by the U.S. authorities. ...

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. ...

Consequently, the applicant is subject to Article 1E of the Convention [17]   The RPD also analyzed the male applicant’s fear of returning to Brazil. ... RAD decision [22]   The RAD confirmed the RPD’s reasoning and conclusions that the male applicant is covered by Article 1E of the Convention. ... 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. ...

(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. ...

In this regard the plaintiff made various arguments, which may be summarized as follows: the conditions set forth in Article 15 of the Convention have been met; using section 7 of the Income Tax Act to interpret the language of Article 15 of the Convention means that benefits received on realization of share purchase option rights are “salaries, wages and other similar remuneration” as provided in Article 15 of the Convention; the Convention must be given a broad and liberal interpretation; the Convention must be applied before any domestic legislation to the same effect; and a presumption created by domestic legislation is inconsistent with the provisions of the Convention. ... As the wording wages, salaries and other remuneration" is not defined anywhere in the Convention, reference must accordingly be made to the Income Tax Act to determine its meaning as provided in Article 3(2) of the Convention. ... As Article 15 of the Convention refers only to “remuneration”, and we are dealing with income other than remuneration in the case at bar, it contended, the Convention cannot apply here as a solution to the first point at issue. ...

There is no definition of the term “Industrial and commercial profits” in such convention. In such event paragraph 11(2) of the convention refers the interpretation to the laws of Canada. ... 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. ...

Articles I and II of the Convention are as follows: Article I An enterprise of one of the contracting States is not subject to taxation by the other contracting State in respect of its industrial and commercial profits except in respect of such profits allocable in accordance with the Articles of this Convention to its permanent establishment in the latter State. ... The taxes referred to in this Convention are: (b) for Canada: the Dominion income taxes, including surtaxes, and excess-profits taxes. 3. ... (c) the term ‘dividends’, as used in this Convention, shall include all distributions of the earnings or profits of corporations.” ...

Relevant statutory and international convention provisions Canada-U.S. ... Income Tax Convention (1980). Articles 31 and 32 of the Vienna Convention on the Law of Treaties (Can. ... In sum, the intentions of the drafters of the Convention and the other extrinsic materials demonstrate that Norsk is not a resident under the Convention. ...