R. v. Melford Developments Inc., 82 DTC 6281, [1982] CTC 330, [1982] 2 SCR 504 -- summary under Article 11

The exclusion in Article III(5) of the Canada - Germany Income Tax Agreement Act, 1956 of "income (e.g. dividends interest, rents or royalties) derived from sources within" Canada from the industrial or commercial profits of a German enterprise did not apply to guarantee fees paid to a German bank because such fees did not constitute "interest" under the ordinary meaning (in 1956) of that word, and the 4 words after "e.g." were an exhaustive list of what was meant by "income".