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  [182‑183] [189]   Cases Cited   By LeBel J.   Distinguished:   R. v. ... Canada (Attorney General), [1998] 1 S.C.R. 841.   Statutes and Regulations Cited   Canadian Charter of Rights and Freedoms, ss. 1  , 7   to 14  , 8  , 9  , 10   (a), (b), 11   (d), 24  , 32  .   ... C‑46, ss. 6(2)  , 7  , 7(3.7)   to 7(3.75)  , (4.1)  , 117.02(1)  , (2)  , 199(2)  , 254(2)   to (4)  , 269.1(1)  , 462  , 487   to 489  , 495(1)  , (2)  . ...

GULLBRIDGE There are four items of expenditure relating to these agreements:       Decision in     Departmental Exchequer Item Period of Expenditure Decision Court I. $ 10,512.05 Prior to November 14, 1950, date of incorporation of Gullbridge                              Disallowed   Allowed II. $ 4,953.73 From November 14, 1950, to December 31, 1950   Disallowed   Allowed III. $247,243.88 1951 Disallowed   Disallowed IV. $ 56,047.26 1952 Disallowed   Disallowed The Minister appeals the allowance of the first two items and Falconbridge appeals the disallowance of the second [Page 115] two. ... There are four items of expenditure relating to these agreements: RAMBRIDGE       Decision in     Departmental Exchequer Item       Period of Expenditure Decision Court V. $20,435.41           1950      Disallowed     Allowed VI. $15,123.57 From January 1, 1951 to February 16, 1951, date of execution of Rambridge Agreement       Disallowed                             Allowed VII. $13,765.73 From February 1, 1951 to December 31, 1951     VIII. $13,677.6           1952     The learned trial judge in his reasons for judgment in dealing with items V and VI adopted the same reasoning as he did in dealing with items I and II. ... Particulars of the items are as follows: JAWTAM       Decision in     Departmental Exchequer Item Period of Expenditure Decision Court IX. $6,991.89 Until October 16, 1952     X. $6, 221.00 October 17, 1952 to the end  of the year.     ...

Canada (National Revenue), 2025 SCC 13     Appeal Heard: November 5, 2024 Judgment Rendered: April 17, 2025 Docket: 40782   Between:   Izabela Piekut Appellant   and   His Majesty The King in Right of Canada, as represented by the Minister of National Revenue Respondent  - and-   Attorney General of Ontario, Attorney General of Quebec, His Majesty The King in Right of the Province of British Columbia, as represented by the Minister of Finance, Canadian Alliance of Student Associations and Canadian Association of Insolvency and Restructuring Professionals Interveners       Coram: Wagner C.J. and Karakatsanis, Côté, Rowe, Martin, Kasirer, Jamal, O’Bonsawin and Moreau JJ.   ... (Martin and Moreau JJ. concurring)     Note: This document is subject to editorial revision before its reproduction in final form in the Canada Supreme Court Reports.           ... The reasons of Karakatsanis, Martin and Moreau JJ. were delivered by                    Karakatsanis J. — I.                ...

An allowance with respect to a timber limit is provided for in sec. 5(1) (a) of the Income War Tax Act, R.S.C. 1927, c. 97, and amendments thereto, the material part of which reads: 5. (1) "Income" as hereinbefore defined shall for the purpose of this Act be subject to the following exemptions and deductions:— (a) The Minister in determining the income derived from * * * timber limits may make such an allowance for the exhaustion of the * * * timber limits as he may deem just and fair * * * This section was under review in D. ... McCool of $35,000, that the depletion allowable will be the result of dividing $35,000 by the total cruise and multiplying by the cut during the period * * * In considering the appeal the Minister had before him the following facts: T. ... The statute is explicit: 5. (1) * * * (a) The Minister * * * may make such an allowance * * * as he may deem just and fair * * * The general language of sec. 66, conferring the exclusive jurisdiction upon the Exchequer Court, is circumscribed and limited by such phrases as "subject to the provisions of this Act * * *" and "determine all questions that may arise in connection with any assessment * * *". ...

Income Tax Commissioner, [1937] A.C. 685, at 695-6; Ward & Co. Ltd. v. ... " Lord Macmillan said at pp. 695-696:— Their Lordships recognize, and the decided cases show, how difficult it is to discriminate between expenditure which is, and expenditure which is not, incurred solely for the purpose of earning profits or gains. * * * In short, the obligation to make these payments was undertaken by the appellants in consideration of their acquisition of the right and opportunity to earn profits, that is, of the right to conduct the business, and not for the purpose of producing profits in the conduct of the business. * * * * * In the case of Robert Addie & Sons' Collieries, Ld. v. ... The nature of the trade is to be considered. * * * In the present case I think that the loss sustained by the appellants was not really incidental to their trade as inn-keepers, and fell upon them in their character, not of traders, but of householders. ...

Canada (Attorney General), 2024 SCC 24     Appeal Heard: November 9, 2023 Judgment Rendered: June 28, 2024 Docket: 40346   Between:   Iris Technologies Inc. Appellant   and   Attorney General of Canada Respondent       Coram: Karakatsanis, Côté, Rowe, Martin, Kasirer, Jamal and O’Bonsawin JJ.   ... (Karakatsanis and Rowe JJ. concurring)     Note: This document is subject to editorial revision before its reproduction in final form in the Canada Supreme Court Reports.           ...

Canada   Neutral citation:  2004 SCC 15.   File No.:  29416.   2003:  November 14; 2004:  March 4.   ... on appeal from the federal court of appeal   Income tax — Income from employment — Deductions — Sales expenses — Purchase of client list — Financial advisor borrowing money to purchase colleague’s client list — Whether payment to purchase client list and interest paid on borrowed funds deductible — Whether payments were “on account of capital” — Income Tax  Act, R.S.C. 1985, c. 1 (5th Supp  .), s. 8(1)   (f).   ... II, s. 5(1)], (j) [idem, ss. 5(4)  , 5(5)  ], (2), 9(1), 18(1)(a), (b), 20(1)(a), (b), (c) [idem, s. 15(1)  ].   ...

His will, after sundry bequests, gave the residue of his estate to his executors and trustees upon trusts to sell and convert, to pay legacies, to invest, to pay an annuity, and “(e) to divide the balance of the income * * * into three equal parts and to pay or apply one of such parts, or so much thereof as my executors and trustees in their discretion deem advisable, in or towards the support, maintenance and education of each of my children until they respectively attain the age of 25 years, or until the period fixed for the distribution of the capital of my estate which ever event shall last happen, provided that any portion of any child’s share not required for his or her support, maintenance and education shall be re-invested * * * and form part of the residue of my estate given and bequeathed to such child; (ƒ) After the death or remarriage of my wife, whichever event shall first happen, to divide the residue of my estate equally between such of my three children as shall attain the age of 25 years, as and when they respectively attain that age, provided that if any of the said children shall have died before the period of distribution arrives, leaving a child or children, such children shall take the share in my estate which his or her parent would have taken had he or she survived the period of distribution * * *.” ... By Notice of Assessment dated the 1st day of March, 1930, the appellant [appellant in the Exchequer Court—the present respondent] was assessed for Income Tax upon the undistributed income, not used in the maintenance of the children under clause (e) in paragraph 9 of the will, from said residuary estate as follows:— Year Taxable Income Tax 1917........... $ 6,508 94 $ 40 18 1918........... 45,378 57 3,469 16 1919........... 57,766 57 8,152 87 1920........... 90,167 28 20,394 78 1921........... 166,896 28 62,508 50 1922........... 205,433 09 85,438 34 1923........... 173,036 85 66,119 16 1924........... 222,788 25 96,372 10 1925........... 271,469 55 97,321 29 1926........... 352,884 04 121,063 95 1927........... 436,480 86 139,366 65 1928........... 392,875 10 122,649 04 * * * * * *.” ... —It is quite plain, I think, that a child does not take, under paragraph 9, subparagraph (ƒ), unless it attains the age of twenty-five years. ...

By the Valuation (Ireland) Act, 1852, s. 2, the valuing authority was directed "to distinguish all hereditaments and tenements, or portions of the same * * * used for charitable purposes * * * and all such hereditaments or tenements, or portions of the same, so distinguished, shall, so long as they continue to be * * * used for the purposes aforesaid, be deemed exempt from all assessment. ... For instance, it might well be said that * * * the establishment of a newspaper conducted on religious or high moral principles * * * would be purposes conducive to the good of religion. ... & C. 410. 52 (1830) 1 B. & Ad. 365. 53 (1845) 7 Q.B. 976; 115 E.R. 756. 54 (1836) 2 M. ...

., 2019 SCC 57, [2019] 4 S.C.R. 138       SUPREME COURT OF CANADA   Citation: Montréal (City) v. ... Appellant   and   Richard Thériault and Ville de Montréal Respondents   Official English Translation   Coram: Wagner C.J. and Abella, Moldaver, Karakatsanis, Gascon, Côté, Brown, Rowe and Martin JJ.   ... (Moldaver J. concurring)             m ontréal (city) v. octane Ville de Montréal                                                                                             Appellant v. ...