illiam A. Dudney is a resident of the United States. In 1994 and 1995, he earned income by performing certain services in Canada as an independent contractor. In his Canadian tax returns for those years, he claimed that his income was exempt from Canadian tax. His claim for exemption was based on Article XIV of the Canada-United States Income Tax Convention (1980) (the "Convention"), enacted as Schedule I to the Canada-United States Convention Act, 1984