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.), rev'd by 86 DTC 6432, [1986] 2 CTC 288 (Ont CA), briefly aff'd by 88 DTC 6273, [1988] 2 CTC 1, [1988] 1 S.C.R. 669-- summary under Paragraph 11(d) Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Paragraph 11(d) It was indicated that the statement in S.244(4) that the Minister's certificate as to the day on which sufficient evidence of the occurrence of an offence came to his knowledge "is conclusive evidence thereof", is not rendered inoperative under SS.7 or 11(d) of the Charter. ...

MNR, 93 DTC 92, [1992] 2 CTC 2673, [1992] 2 CTC 2208, [1993] DTC 88 (TCC)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

Canada, 90 DTC 6447, [1990] 2 SCR 338, [1990] 2 CTC 262-- summary under Subsection 231.3(1) Summary Under Tax Topics- Income Tax Act- Section 231.3- Subsection 231.3(1) The provisions of ss.231.3 and 239 are by their nature criminal law. ...

The Queen, 85 DTC 5330, [1985] 2 CTC 131 (FCTD), aff'd 86 DTC 6122, [1986] 2 CTC 69 (FCA)-- summary under Subsection Old 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- Old- Subsection Old 247(2) Cullen, J. rejected the appellant's argument "that the language employed in subsection 247(2)... is so vague and uncertain, and so subject to discretionary determination, that it cannot be regarded as a law, and secondly, 247(3) does not entitle a taxpayer to a full challenge as to the basis upon which the Minister of National Revenue may issue a direction under 247(2)". ...

Fries, 90 DTC 6662, [1990] 2 SCR 1322, [1990] 2 CTC 439-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) payment from union to support another strike was non-taxable Amounts received by an employee of the Saskatchewan Liquor Board from the Saskatchewan Government Employees' Union (the "SGEU") in consideration of his agreement in support of a strike by government employees who were not Liquor Board employees, to withdraw his services from the Liquor Board, were not taxable to him as income from a source. ...

The Queen, 84 DTC 6267, [1984] CTC 319 (FCA), rev'd 86 DTC 6526, [1986] 2 CTC 465, [1986] 2 SCR 522-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business investment portfolio of manufacturing co gave rise to income from property "[F]or purposes of the Income Tax Act, the fact that an activity is engaged in for the purpose of making a profit cannot be decisive of the question whether income from it has its source in 'business', on the one hand, or in 'property' on the other. ...

Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312, [1994] 2 CTC 25-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning In finding that the taxpayers are entitled to a deduction under s. 20(14)(b) because they complied with the expressed conditions of the provision, Iacobucci J. stated (p. 6321): "Where the words of the section are not ambiguous, it is not for this Court to find that the appellants should be disentitled to a deduction because they do not deserve a 'windfall', as the respondent contends. ...

Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312, [1994] 2 CTC 25-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity In finding that the taxpayers are entitled to a deduction under s. 20(14)(b) because they complied with the expressed conditions of the provision, Iacobucci J. stated (p. 6321): Where the words of the section are not ambiguous, it is not for this Court to find that the appellants should be disentitled to a deduction because they do not deserve a 'windfall', as the respondent contends. ...

Canada, 95 DTC 5389, [1995] 2 SCR 802, [1995] 2 CTC 64-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions Before referring to various extrinsic materials, Iacobucci J. stated (at p. 5396) that "reviewing the intentions of the drafters of a taxation convention is a very important element in delineating the scope of the application of that treaty" and "that, in ascertaining these goals and intentions, a court may refer to extrinsic materials which form part of the legal context (these include accepted model conventions and official commentaries thereon) without the need first to find an ambiguity before turning to such materials. ...

MNR, 92 DTC 2240, [1992] 2 CTC 2787, [1992] 2 CTC 2125, [1992] DTC 2235 (TCC)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership It was found that by an agreement dated January 16, 1985, the taxpayer had disposed of his shares of a corporation to a shareholder. ...