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., 95 DTC 5168, [1995] 2 CTC 86 (FCA), rev'd 96 DTC 6309, [1996] 2 SCR 161-- summary under Subsection 45(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 45(2) The enactment of s. 249(4) in 1987, whose provisions would have prevented the taxpayer from acquiring a corporation with an accrued but unrealized loss on inventory and receiving the benefit of that loss on a rollover basis under s. 88(1), was found to have not necessarily altered the previous state of the law in light of s. 45(2) of the Interpretation Act. ...

The Queen, 86 DTC 6251, [1985] 2 CTC 320 (FCTD), aff'd 87 DTC 5409, [1987] 2 CTC 240 (FCA)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing The taxpayer was entitled to receive a management fee equal to 10% of the net profits from a shopping centre including gains from its sale. ...

The Queen, 93 DTC 1449, [1993] 2 CTC 3189 (TCC), ultimately aff'd 96 DTC 6309, [1996] 2 S.C.R. 161-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense S.18(1)(a) could not apply to deny a loss realized by the taxpayer on the sale of inventory acquired by it pursuant to an s. 88(1) wind-up of its subsidiary because inter alia the deemed cost of the land to the taxpayer under an s. 88(1) could not be characterized as an "outlay or expense" of the taxpayer. ...

Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175-- summary under Comparison of Provisions Summary Under Tax Topics- Statutory Interpretation- Comparison of Provisions "income" has same meaning in different sections In response to a submission of the Minister that in the absence of a separate definition for the section, "income" had a different meaning in s. 106 of the Corporations Tax Act from its meaning in Part II of that Act in which the section appeared, Wilson J. stated: "The difficulty with this position, as I see it, is that a taxing statute is a highly technical piece of legislation which requires an interpretation that will ensure certainty for the taxpayer. ...

.), 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 Subsection 244(4) Summary Under Tax Topics- Income Tax Act- Section 244- Subsection 244(4) S.244(4) "leaves it entirely in the hands of the Minister to state when in his 'opinion' sufficient information was brought to his knowledge to justify prosecution. ...

The Queen, 85 DTC 5473, [1985] 2 CTC 275 (FCTD), aff'd 86 DTC 6335, [1986] 2 CTC (FCA)-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital The plaintiff, which purchased the exclusive right to sell Century 21 franchises to licensed real estate brokers, was found to be in the business of selling real estate franchises, and such sales accordingly gave rise to business income rather than the receipt of credits to its cumulative eligible capital. ...

The Queen, 85 DTC 5373, [1985] 2 CTC 111, [1985] 2 S.C.R. 46-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity presumption of relief for business expenditures Estey J stated (at para. 33): [I]f the interpretation of a taxation statute is unclear, and one reasonable interpretation leads to a deduction to the credit of a taxpayer and the other leaves the taxpayer with no relief from clearly bona fide expenditures in the course of his business activities, the general rules of interpretation of taxing statutes would direct the tribunal to the former interpretation... ...

The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)-- summary under Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Reasonable Expectation of Profit A taxpayer's expenses may be deductible even if "there is neither immediate income nor an immediate source of income in his business. ...

The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)-- summary under Oversight or Investment Management Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit A taxpayer's expenses may be deductible even if "there is neither immediate income nor an immediate source of income in his business. ...