Section 227.1

Subsection 227.1(1) - Liability of directors for failure to deduct

Cases

Attorney General of Canada v. McKinnon, 2000 DTC 6593 (FCA)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) turnaround prospects 148

The Queen v. Corsano, 99 DTC 5658 (FCA)

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Clarke v. The Queen, 2000 DTC 6230 (FCTD)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 94

Parton v. The Queen, 99 DTC 738 (TCC)

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The Queen v. Leung, 93 DTC 5467 (FCTD)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(3) reassessment valid notwithstanding missing particulars 82
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) 82

See Also

Jobin v. The Queen, 2015 DTC 1096 [at 560-561], 2014 TCC 326

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MacDonald v. The Queen, 2014 DTC 1212 [at 3839], 2014 TCC 308

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) not de facto director where unwittingly named to 3rd parties as director 330

Qian v. The Queen, 2014 DTC 1024 [at 2639], 2013 TCC 386

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Chell v. The Queen, 2013 DTC 1055 [at 299], 2013 TCC 29

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) 204

Nachar v. The Queen, [2011] GSTC 12, 2011 TCC 36

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) failure to remit was due to confusion on 3rd party responsibilities and other sales handled properly 109
Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) director can challenge substantive merits of underlying assessment 107

Lequier v. The Queen, 2010 TCC 474, 2010 DTC 1321 [at 4219]

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 101

Hartrell v. The Queen, 2006 DTC 3548, 2006 TCC 480

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) 73

Buckingham v. The Queen, 2010 TCC 247, rev'd 2011 FCA 142

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Tax Topics - Statutory Interpretation - Provincial Law 71

McDougall v. The Queen, 2001 DTC 2651 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 29

Mosier v. The Queen, [2001] GSTC 124, Docket: 96-3504-GST-G (TCC),

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) 281

Dirienzo v. The Queen, 2000 DTC 2230 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 44

Wheeliker v. The Queen, 98 DTC 1110 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 58

Myers v. The Queen, 98 DTC 1057 (TCC)

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Roll v. MNR, 92 DTC 1446 (TCC)

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Laxton v. MNR, 89 D.T.C. 629 (TCC)

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Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) GP responsible for LP source deductions 207

Administrative Policy

4 December 2014 Memorandum 2014-0531251I7 - Directors' Liability

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) directors of GP potentially liable for GST remittance failures of LP 122
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) GP generally liable for source deduction failures of LP 79

9 August 2012 T.I. 2012-0446051E5 - Director's liability for provincial assessment

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88 C.R. - F.Q. 7

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85 C.R. - Q.81

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84 C.R. Q.7

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Articles

Brian M. Studniberg, "Identifying the De Facto Director", Canadian Tax Journal, (2015) 63:4, 1073-95

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Subsection 227.1(2) - Limitations on liability

Paragraph 227.1(2)(a)

Cases

Kyte v. The Queen, 96 DTC 6050 (FCTD), aff'd 97 DTC 5022 (FCA)

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See Also

Walsh v. The Queen, 2009 DTC 1372, 2009 TCC 557

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) 101

Gaitens v. The Queen, 93 DTC 54 (TCC)

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Administrative Policy

86 C.R. - Q.88

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Paragraph 227.1(2)(b)

Cases

Madison v. The Queen, 2012 DTC 5072 [at 6935], 2012 FCA 80

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Tax Topics - General Concepts - Evidence hearsay evidence in informal procedure case 135

Kennedy v. MNR, 91 DTC 1037 (TCC), briefly aff'd 92 DTC 6380 (FCA)

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See Also

Savoy v. The Queen, [2011] GSTC 15, 2011 TCC 35

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(2) - Paragraph 323(2)(b) mandatory 6 month deadline applied even where corporate dissolution by Ontario Ministry 230
Tax Topics - Excise Tax Act - Section 323 - Subsection 323(5) director resignation not effective for failure to hold first shareholders' meeting 115
Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) director had right to challenge underlying assessment 98

Subsection 227.1(3) - Idem [Limitations on liability]

Cases

Gariepy and Chriss v. The Queen, 2014 TCC 254

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) unsigned written resignations were effective 138

Liddle v. The Queen, 2011 DTC 5083 [at 5838], 2011 FCA 159

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) 58

The Queen v. Buckingham, 2011 DTC 5078 [at 5810], 2011 FCA 142

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Smith v. The Queen, 2001 DTC 5226 (FCA)

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Hanson v. The Queen, 2000 DTC 6564 (FCA)

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Attorney General of Canada v. McKinnon, 2000 DTC 6593 (FCA)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) receiver supercedes directors 96

The Queen v. Corsano, 99 DTC 5658 (FCA)

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Berdugo v. The Queen, 99 DTC 5424 (FCTD)

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Clarke v. The Queen, 2000 DTC 6230 (FCTD)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) 132

Short v. The Queen, 99 DTC 5371 (FCTD)

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Soper v. The Queen, 97 DTC 5407 (FCA)

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Tax Topics - Statutory Interpretation - Other/Conflicting Statutes presumption of coherence 32
Tax Topics - Statutory Interpretation - Similar Statutes presumed coherence in federal statutes 38

Wilson v. The Queen, 96 DTC 6417 (FCTD)

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Shindle v. The Queen, 95 DTC 5502 (FCTD)

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Robitaille v. The Queen, 90 DTC 6059 (FCTD)

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See Also

Maxwell v. The Queen, 2015 DTC 1102 [at 610], 2015 TCC 74

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Other locations for this summary
Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) expectation of future payments, to which the taxpayer was clearly entitled, did not constitute due diligence]

Roitelman v. The Queen, 2014 DTC 1129 [at 3348], 2014 TCC 139

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D'Amore v. The Queen, 2013 DTC 1005 [at 33], 2012 TCC 373,

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) 265

Deakin v. The Queen, 2012 DTC 1231 [at 3634], 2012 TCC 270

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) 142

Martin v. The Queen, 2012 DTC 1253 [at 3725], 2012 TCC 239

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) 155

Seier v. The Queen, 2010 DTC 1344 [at 4313], 2010 TCC 495

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Lequier v. The Queen, 2010 TCC 474, 2010 DTC 1321 [at 4219]

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) 76

Pascoal v. The Queen, 2010 DTC 1010 [at 2578], 2009 TCC 608

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Burton v. The Queen, 2006 DTC 2001, 2005 TCC 762

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People's Stores v. Wise, 2004 SCR 68

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McKinnon v. The Queen, 2004 DTC 2049, 2003 TCC 884

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McDougall v. The Queen, 2001 DTC 2651 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) 76

Dirienzo v. The Queen, 2000 DTC 2230 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) 37

MacDonald v. The Queen, 99 DTC 1108 (TCC)

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Boisvert v. The Queen, 98 DTC 1146 (TCC)

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Wheeliker v. The Queen, 98 DTC 1110 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) 108

Schultheiss v. The Queen, 97 DTC 863 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) 98

Hanson v. The Queen, 97 DTC 796 (TCC)

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Johnstone v. The Queen, 97 DTC 355 (TCC)

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Davies-Edwards v. The Queen, 97 DTC 373 (TCC)

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Hadad v. MNR, 94 DTC 1847 (TCC)

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Davies v. The Queen, 94 DTC 1716 (TCC)

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Ivezic v. MNR, 92 DTC 1066 (TCC)

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Myers v. MNR, 91 DTC 72 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 70

Myers v. MNR, 91 DTC 72 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 70

Vogt v. MNR, 91 DTC 1326 (TCC)

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Van Leenen v. MNR, 91 DTC 1265 (TCC)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 76

Pidskalny v. MNR, 91 DTC 1046 (TCC)

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MacArthur v. MNR, 91 DTC 957 (TCC)

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Byrt v. MNR, 91 DTC 923 (TCC)

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Tax Topics - General Concepts - Estoppel 153

Sheremeta v. MNR, 91 DTC 867 (TCC)

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Collins v. MNR, 91 DTC 819 (TCC)

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Perry v. MNR, 91 DTC 696 (TCC)

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Noonan v. MNR, 91 DTC 416 (TCC)

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Golfman v. MNR, 90 DTC 1863 (TCC)

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Deschènes v. MNR, 90 DTC 1342 (TCC)

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Champeval v. MNR, 90 DTC 1291 (TCC)

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Swertz v. MNR, 90 DTC 1056 (TCC)

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McCullough v. MNR, 89 DTC 446 (TCC)

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Merson v. MNR, 89 DTC 22 (TCC)

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Beutler v. MNR, 88 DTC 1286 (TCC)

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Cybulski v. The Queen, 88 DTC 1531 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) 167

Edmondson v. MNR, 88 DTC 1542 (TCC)

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Fancy v. MNR, 88 DTC 1641, [1988] 2 CTC 2256 (TCC)

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Quantz v. MNR, 88 DTC 1201 (TCC)

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Fraser v. MNR, 87 DTC 250 (TCC)

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Administrative Policy

88 C.R. - "Director's Liability"

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88 C.R. - F.Q.5

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88 C.R. - F.Q.6

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88 C.R. - F.Q. 8

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87 C.R. - Q.77

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87 C.R. - Q.78

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87 C.R. - Q.81

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86 C.R. - Q.86

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86 C.R. - Q.87

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IC 89-2 "Directors' Liability - Section 227.1 of the Income Tax Act"

Articles

Fien, "Directors' Liability and Indemnifications, Section 160 Assessments and Ordinary Course of Business Provisions", 1992 Conference Report, c. 53.

Fulcher, "Section 227.1 of the Income Tax Act and the Director's Duty of Care in BCA Jurisdictions: Some Lessons From the Corporate Governance Debate of the Last Twenty-Five Years", Canadian Petroleum Tax Journal, Spring, 1992, p. 17.

Moskowitz, "Directors' Liability: An Update", 1991 Conference Report, c. 47.

Heinrich, "Judicial Response to Director's Liability and Crown Garnishment Priorities", 1991 British Columbia Tax Conference, Volume 1.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 224 - Subsection 224(1.2) 0

Moskowitz, "Directors' Liability under Income Tax Legislation and Other Related Statutes", 1990 Canadian Tax Journal, p. 537.

Subsection 227.1(4) - Limitation period

Cases

Gariepy and Chriss v. The Queen, 2014 TCC 254

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) reasonable belief in resignation constituted a due diligence defence, "economic necessity" defence rejected 228

Létourneau v. The Queen, 2012 DTC 5044 [at 6777], 2011 FCA 354

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Butterfield v. The Queen, 2009 DTC 1382 [at 2108], 2009 TCC 575, aff'd 2011 DTC 5005 [at 5510], 2010 FCA 330

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Re Blackwater Marine Inc., 2010 DTC 5087 [at 6877], 2010 BCSC 340

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The Queen v. Kalef, 96 DTC 6132 (FCA)

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The Queen v. Wellburn, 95 DTC 5417 (FCTD)

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See Also

Marra v. The Queen, 2016 DTC 1028 [at 2696], 2016 TCC 24

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(5) two years for a director’s derivative assessment ran from handing a resignation to the company’s lawyer, who did nothing with it 143

Bekesinski v. The Queen, 2014 DTC 3604 [at 1169], 2014 TCC 245

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Tax Topics - General Concepts - Onus unspecific pleadings were more readily demolished, improbable allegations treated with greater care 185

Bohbot-Gangnon v. The Queen, 2013 DTC 1185 [at 998], 2013 TCC 128

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Pfitis, 2013 DTC 1030 [at 141], 2012 TCC 414

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Walsh v. The Queen, 2009 DTC 1372, 2009 TCC 557

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Moll v. The Queen, 2008 DTC 3420, 2008 TCC 234

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Hamilton v. The Queen, 2007 DTC 121, 2006 TCC 603

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Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) withholding not reduced if no substantive liability 159

Hartrell v. The Queen, 2006 DTC 3548, 2006 TCC 480

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) 119

Schultheiss v. The Queen, 97 DTC 863 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 49

Crossley v. MNR, 91 DTC 827 (TCC)

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Nagy v. MNR, 91 DTC 993 (TCC)

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Larocque v. MNR, 91 DTC 899 (TCC)

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McConnachie v. MNR, 91 DTC 873 (TCC)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 21

Hawkins v. MNR, 91 DTC 648 (TCC)

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DeWitt v. MNR, 90 DTC 1027 (TCC)

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Perri v. MNR, 89 DTC 723 (TCC)

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Cybulski v. The Queen, 88 DTC 1531 (TCC)

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 167

Administrative Policy

88 C.R. - Q.81

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85 C.R. - Q.13

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Subsection 227.1(7) - Contribution

Cases

Adams v. Anderson, 2011 ONCA 381

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Tax Topics - Excise Tax Act - Section 323 - Subsection 323(8) 113