The Applicant, Conrad Black, made an application for the determination of a question of law under section 58 of the Tax Court of Canada Rules (General Procedure) prior to the hearing of his case. (a) Issue. The issue was:
| - | whether or not article 4(2) of the Canada - United Kingdom Income Tax Treaty (1978) (the Treaty), which deemed Black (according to the tie-breaker rule) to be a resident of the United Kingdom for the purposes of the Treaty overrides… |