Retroactivity/Retrospectivity

Cases

CNG Producing Co. v. Provincial Treasurer (Alberta), 2002 DTC 7537 (Alta CA)

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The Queen v. Corbett, 99 DTC 5624, 1999 CanLII 9367 (FCA)

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Hokhold v. The Queen, 93 DTC 5339 (FCTD)

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Roseland Farms Ltd. v. The Queen, 92 DTC 6417 (FCTD)

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First Fund Genesis Corp. v. The Queen, 91 DTC 5361 (FCTD)

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Placer Dome Inc. v. The Queen, 91 DTC 5115 (FCTD)

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Aluminium Enterprises Ltd. & Ors. v. The Commissioners of Income Tax, [1985] BTC 550 (PC)

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Laurentide Rendering Inc. v. The Queen, 84 DTC 6153 (FCTD), aff'd 88 DTC 6331, [1988] 2 CTC 200 (FCA)

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Davis v. The Queen, 80 DTC 6056, [1980] CTC 88 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 48 - Subsection 48(1) 87

Beique v. The Queen, 78 DTC 6452, [1978] CTC 646, aff'd 81 DTC 5050 [1981] CTC 75 (FCA)

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Agnew Estate v. The Queen, 78 DTC 6237, [1978] CTC 351 (FCA)

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Barkman Developments Ltd. v. MNR, 67 DTC 5227, [1967] CTC 325, briefly aff'd 67 DTC 5306 (SCC)

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Procureur Général du Canada v. La Compagnie de Publication La Presse, Ltée, 66 DTC 5492, [1967] S.C.R. 60

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See Also

Chevron Australia Holdings Pty Ltd v Commissioner of Taxation, [2017] FCAFC 62

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) cross-border loan made on arm’s length terms would have benefited from a parent guarantee or other security 640
Tax Topics - Treaties - Income Tax Conventions - Article 9 cross-border loan interest improperly reflected lack of security 367

Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Revenue Rule pre-Treaty revenue rule 122
Tax Topics - Treaties Vienna convention approach applies to non-signatories 197
Tax Topics - Statutory Interpretation - Revenue Rule 116
Tax Topics - Treaties - Income Tax Conventions - Article 26A new tax collection Article applied to old tax debts 222

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt payment by direction 133
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.12) 186
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) limited scope of PUC provisions reflected a policy choice 283

MIL (Investments) S A v. The Queen, 2006 DTC 3307, 2006 TCC 460, aff'd 2007 FCA 236

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Upper Lakes Shipping Ltd. v. MNR, 92 DTC 2381 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 17 - Subsection 17(1) 194

Articles

Verchere, "Jurisprudence from Foreign Jurisdictions", 1992 Conference Report, pp.51:33-51:50

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