Zhao – Tax Court of Canada finds that the meaning of a definition is informed by words in the defined term

In Wunderlich, Webb J (while still in the Tax Court) found that the meaning of a defined term is informed only by the words in the definition rather than by the words in the defined term so that, for example, a "small business corporation" is not necessarily "small" – or, in the case before him, a "new work location" under the employee moving expense rules does not have to be a different location than the previous work site, as there is no requirement to that effect in the definition itself.

Masse DJ disagreed, indicating that if the legislative drafter used "new" in the defined term, there must have been a new work location in mind. (By the way, no one argued that "new" modifies "work" rather than "location" so that the taxpayer satisfied the defined term (as well as the definition) because he moved due to his "new" (more onerous) work duties.)

Neal Armstrong. Summary of Zhao v. The Queen, 2015 TCC 124 under s. 248(1) – eligible relocation.