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the genuine shared expectations of the contracting parties".
Maximov v. United States, 299 F.2d 565, 568 (2d Cir. 1962), affd.
373 U.S. 49 (1963). Courts liberally construe treaties to give
effect to their purpose. United States v. Stuart, 489 U.S.
353, 368 (1989); Bacardi Corp. of Am. v. Domenech, 311 U.S. 150,
163 (1940). Even where a provision of a treaty fairly admits of
two constructions, one restricting, the other enlarging, rights
which may be claimed under it, the more liberal interpretation is
to be preferred. United States v. Stuart, supra at 368. In
construing a convention, we give the language its ordinary
meaning in the context of the convention, unless a more
restricted sense is clearly intended. De Geofroy v. Riggs, 133
U.S. 258, 271 (1890). Finally, it is well settled that when a
convention and a statute relate to the same subject, courts will
always attempt to construe them so as to give effect to both.
Estate of Burghardt v. Commissioner, 80 T.C. 705, 713 (1983),
affd. without published opinion 734 F.2d 3 (3d Cir. 1984).
"Although not conclusive, the meaning attributed to treaty
provisions by the Government agencies charged with their
negotiation and enforcement is given great weight". United
States v. Stuart, supra at 369 (citing Kolovrat v. Oregon, 366
U.S. 187, 194 (1961)).
The Model Double Taxation Convention on Income and on
Capital, Report of the O.E.C.D. Committee on Fiscal Affairs
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