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On their proper interpretation, the words of Treaty 8 and the discussions between the Indians and the Commissioners could not create a tax exemption based on racial discrimination because such an interpretation would cause a breach by Canada of Treaties, Covenants, Charters, Conventions and Declarations entered into or adhered to by Canada. 4. ...

(tax benefit) opération Sont assimilés à une opération une convention, un mécanisme ou un événement. ...

Specifically, the Crown submits that CPRC’s representations, conduct, or lack thereof during the last 140 years give rise to the defences of estoppel (promissory estoppel and estoppel by convention), waiver by election, abandonment, laches, and acquiescence. [751] CPRC argues that equitable defences do not apply. ...