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 the provisions of the Canadian Income Tax Act so as to prevent the applicant from being assessed under the Canadian...