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Respondent     REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Calgary, Alberta, on June 13, 2007) PELLETIER J.A. [1]                In order to succeed in this appeal, the appellant Her Majesty the Queen must persuade us that one transaction in the series of transactions in issue is an avoidance transaction, and that the tax benefit achieved by the respondent MIL (Investments) S.A. is an abuse or misuse of the object and purpose of article 13(4) of the Convention between Canada and the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of fiscal Evasion with respect to Taxes on Income and on Capital (the Tax Treaty) ...

  [1]               The issue in this appeal is whether the Appellant is entitled to claim deductions of $22,760.38 pursuant to the Foreign Convention and Tour Incentive Program (“FCTIP”). ...

Les créances prioritaires sont les suivantes et, lorsqu'elles se rencontrent, elles sont, malgré toute convention contraire, colloquées dans cet ordre:     1.     ...

Canada (Citizenship and Immigration), 2014 FC 477 Date: 20140516 Docket: IMM-5045-13 Citation: 2014 CF 477 [ENGLISH TRANSLATION] Ottawa, Ontario, May 16, 2014 PRESENT: The Honourable Justice Martineau BETWEEN: CAROLINA ORTIZ CABRERA WILSON ALEXIS MATEUS GORDILLO NATALIA MATEUS ORTIZ JUAN CAMILO MATEUS ORTIZ LILIANA LAILY MATEUS GORDILLO JORGE ENRIQUE MATEUS PUERTO DORALINA LAYLY GORDILLO DE MATEUS Applicant and THE MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent JUDGMENT AND REASONS [1]   This is an application for judicial review of the decision in which the Refugee Protection Division of the Immigration and Refugee Board of Canada [the Board] stipulated that the applicants, citizens of Colombia, had neither refugee status under the Convention nor the status of persons in need of protection under sections 96 and 97 of the Immigration and Refugee Protection Act, SC 2001, c. 27 [the Act] because there is the possibility of internal flight alternative [IFA] in their country of nationality. [2]   First, the Board must be convinced that, in accordance with the preponderance of probabilities, the applicants for asylum are not at serious risk of being persecuted in the part of the country where there is a possibility of refuge, and second, that it must not be unreasonable for said applicants to find refuge there, given all of the applicants’ circumstances. ...

The Applicant was granted Convention Refugee status at the age of fifteen in June 2003, and Permanent Resident status in Canada in June 2004. [3]   The Applicant had committed: offences comprised of possession of property obtained by crime on October 29, 2007, contrary to paragraph 354(1)(a) of the Criminal Code, RSC, 1985, c C-46 [CC]; failure to comply with conditions of undertaking or recognizance contrary to paragraph 145(3)(b) of the CC on June 20, 2007; possession of substances in schedule II for the purpose of trafficking, contrary to paragraph 5(2)(3)(a) of the Controlled Drugs and Substances Act, SC 1996, c 19, on February 13, 2008, and two further convictions for possession of substances included in schedule II for the purpose of trafficking; also for which he was convicted of robbery, contrary to subsection 344(b) of the CC and several failures to comply with conditions of undertaking, contrary to paragraph 145(3)(b) of the CC. [4]   After the 2014 Opinion of the Minister, the Applicant was convicted of failure to stop as requested by a police officer, contrary to subsection 249.1(01) of the CC; also of dangerous driving, contrary to paragraph 249(01)(a); in addition to resisting police, contrary to subsections 129(a) and 129(d). [5]   Furthermore, on March 2, 2018, for crimes committed on February 25, 2018, the Applicant failed to comply with condition or recognizance, contrary to paragraph 145(3)(a) of the CC; also dangerous driving as per paragraphs 249(01)(a) and 249(02)(a) of the CC; the Applicant also failed to stop as requested by a police officer, contrary to subsection 249.1(01) and paragraph 249.1(02)(a) of the CC; also, resisting police, contrary to subsections 129(a) and 129(d) of the CC. [6]   All of which together constituted a danger opinion; for the latest crimes committed by the Applicant was serving in prison when the danger opinion was rendered. [7]   The delegate’s opinion is reasonable under the circumstances as the danger to the public is considered to be more substantial than any risk to the Applicant. [8]   In addition, the Minister’s delegate did consider the best interests of the children in accordance with the jurisprudence thereon. [9]   The evidence in respect to the children, family, spouse and applicant, was considered as is evident for the Minister delegate’s opinion. ...

First, it found that the applicant had failed to establish a fear of persecution on any of the grounds enumerated in section 96 of the Immigration and Refugee Protection Act, SC 2001, c 27 [IRPA], as Haitian physicians do not constitute a particular social group under the Convention. ...

Bhachu also seeks relief pursuant to article 23(1) of the income tax convention between Canada and the Arab Republic of Egypt (the “Treaty”). ...

For the Minister the situation was:... the deduction for a pension contribution to the British Department of Health and Social Security was properly disallowed as it is not listed as one of the eligible deductions in Subdivision A and E of Division B of the Income Tax Act and is not the subject of an article in the Canada — United Kingdom Tax Convention. ...

There does not appear to be an International Tax Convention between Canada and East Africa. ...

Further, in Ernest G Stickel v MNR, [1972] CTC 210; 72 DTC 6178, it was held that an Information Bulletin published by the Minister which misstated the effect of Article 8(a) of a Tax Convention did not create an estoppel against the Minister. ...