Before determining that the taxpayer was an independent contractor governed by Article XIV of the Canada-U.S. Income Tax Convention rather than providing dependent personal services described in Article XV, Décary J.A. stated (at p. 6867):
"Turning now to the interpretation of the concepts of 'independent contractors' and 'employees' in regard to a contract executed in Canada, one is to be reminded that common law rules will apply if the contract at issue is to be interpreted in accordance with the laws of a province other than Quebec and that the Civil Court of Quebec will apply if the contract at issue is to be interpreted in accordance with the laws of the Province of Quebec."