Treaties — Special kinds of — Double taxation conventions — Convention between Canada and United States, 1942 — Meaning of concept of "permanent establishment therein " — Alien limited partners as maintaining permanent establishment through limited partnership in United States — The law of the United States of America.

Treaties — Interpretation of — Double Taxation Convention between Canada and United States, 1942 — Meaning of concept of “permanent establishment therein” — Alien limited partners as maintaining permanent establishment through limited partnership in United States — The law of the United States of America.