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Convention is the gain which is subject to tax " (p. 5454) the proration of gain under paragraph 9 of Article XIII, was required to be calculated by reference to the period of time that the property in question (a cottage owned by the taxpayer and his previously-deceased wife since 1967) had been held subsequent to December 31, 1971 (the date on which the capital gains became subject to tax) rather than during the whole period of ownership. ...

. … Structures that lead to repetition, over-elaboration of arguments, block quotations, and rhetorical flourishes make submissions diffuse. ...

Nadon J.A. stated (at para. 12): "... a plain reading of both the French and English text of paragraph 8(1)(h.1) of the Act makes it clear that the words 'motor vehicle expenses incurred for travelling in the course of the office...' necessarily require that these expenses be incurred by the taxpayer while performing the duties of his office. ...

Thomson & Associates Ltd. to make a survey of pulp and newsprint pricing discounts and commissions, who obtained the relevant information from members of the industry on the assurance that such information would be protected by the strictest confidentiality. ...

Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose It was noted that the question to be answered under s. 18(1)(a) (unlike S.6(1)(a) of the Income War Tax Act, 1948) is whether the outlay or expense "was incurred for the purpose of gaining or earning income- not ' the income' (which implies a specific source of income) and not 'wholly, exclusively and necessarily...' therefrom, but simply 'for the purpose of...'". ...

General Provisions In finding that paragraph 13(21)(d) rather than 79(c) governed the determination of the proceeds of disposition of a property, Linden J.A. stated (at p. 6576): "... this is not a case where, because of a conflict, the Court must choose to apply a specific provision over a general one in accordance with that well-known principle of statutory interpretation; there is no conflict here. ...

Sarraf considered that a court appeal was a mere continuation of proceedings which had been commenced against the corporation by the Minister’s assessment – but Dawson JA found that Sarraf had failed to consider that the current appeal procedures were quite different from the Income War Tax Act procedures considered in a yet earlier decision. ...

Leonati, [1996] 3 S.C.R. 458 … at paragraph 51). ...

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Canada, 2016 FCA 304-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract pointless to determine whether an instrument is debt for purposes of whole Act The Federal Court of Appeal dismissed the Barejo appeal – but on the grounds that the Rule 58 question posed to the Tax Court was whether the “notes” in question were debts for purposes of the Act rather than for purposes of s. 94.1 thereof. ...