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Subject to paragraph 2, for the purposes of this Convention, a person is a resident of one of the Contracting States if that person is a resident of that State for the purposes of its tax.... 3. ... Indeed, even though the appellant is considered by the respondent to have been ordinarily resident in Canada, he is nevertheless deemed not to have been resident in Canada by virtue of article 4 of the Canada-Australia Tax Convention, referred to above, and subsection 250(5) of the Act, which reads as follows: 250(5)             (5) Deemed non-resident. ... I do not find, on the evidence, that the appellant had a permanent home available to him in Canada during his stay in Australia. [19]     The commentary by the OECD (Organisation for Economic Co-operation and Development) Committee on Fiscal Affairs on article 4 (regarding the definition of resident) of the Model Tax Convention on Income and on Capital, in Model Tax Convention on Income and on Capital, condensed version, dated January 28, 2003, says the following at paragraphs 11, 12 and 13 at page 80 (see Respondent's Authorities, Tab 15): 11.        ...

There are twenty-six concluded and ten proposed tax conventions, treaties or agreements between Canada and other nations of the world. ... [Treaty interpretation] Contrary to an ordinary taxing statute a tax treaty or convention must be given a liberal interpretation with a view to implementing the true intentions of the parties. ... Article 31 of the Vienna Convention on the Law of Treaties (1969) to which Canada subscribed governs the general rule of interpretation to be applied. ...

Hafamo’s first cousin and some other individuals sponsored his application for permanent residence under the Convention Refugee Abroad class and Humanitarian-Protected Persons Abroad class. ... Hafamo was not a member of the Convention Refugee Abroad class or the Humanitarian-Protected Persons Abroad class. ... It is not equivalent to the definition of a refugee, or the grounds for exclusion from refugee status [citation omitted], both of which are rooted in the Refugee Convention itself. ...

Desir, is excluded from protection under Article 1E of the United Nations Convention Relating to the Status of Refugees [Article 1E], and the Applicants are not Convention refugees or persons in need of protection. ... RPD’s Decision [6]   The RPD concluded the Applicants were not Convention refugees or persons in need of protection. ... It further found that Miss Bercy was not a Convention refugee as she did not have a well-founded fear of persecution on a Convention ground in Chile. ...