Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1)

Suggests that the phrase "liable to" can create a liability to tax; and that, in any event, the creation of liability to tax, viewed as merely an...

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Words and Phrases
liable to
Summary Under
Tax Topics - Income Tax Act - Section 222 - Subsection 222(1) - Tax debt

"Liability" v. "debt" (pp. 716-717)

The distinction so clearly made by Jackett P in Terra Nova Properties [67 DTC 5064] between liability for tax...

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Words and Phrases
liability debt