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TCC (summary)
Williams v. The Queen, 2004 DTC 3549, 2004 TCC 706 -- summary under Subparagraph 8(1)(i)(ii)
Miller J. stated (at p. 3554): "... Paragraph 8(1)(i) does not stipulate that an assistant must be 'required by the contract of employment', but that the payment of salary to an assistant was required by the contract of employment. ...
TCC (summary)
Location Gaétan Lévesque Inc. v. MNR, 91 DTC 1380, [1991] 2 CTC 2795 (TCC) -- summary under Ownership
Lamarre Proulx J. stated (p. 1385): "... The words 'property acquired' must be taken to mean property in which the taxpayer has a right of ownership, or if not such a right, then all the attributes of a right of ownership, as in the case of a conditional sale. ...
FCA (summary)
The Queen v. Gulf Canada Ltd., 92 DTC 6123, [1992] 1 CTC 183 (FCA) -- summary under Paragraph (a)
., 92 DTC 6123, [1992] 1 CTC 183 (FCA)-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (a) no connection betweeen lease payments and exploration In finding that annual rental or other payments to provincial governments made for the purpose of keeping leases or licences to subsurface oil and gas rights current were not CEE, Hugessen J.A. stated (p. 6128): "... ...
FCA (summary)
British Columbia Telephone Co. Ltd. v. The Queen, 92 DTC 6129, [1992] 1 CTC 26 (FCA) -- summary under Hansard, explanatory notes, etc.
In giving relatively little weight to possible inferences to be drawn from Budget Papers, MacGuigan J.A. stated (at p. 6132 and at 6134): "... ...
FCTD (summary)
United News (Wholesalers) Ltd. v. The Queen, 94 DTC 6508, [1994] 2 CTC 180 (FCA) -- summary under Capital Loss v. Loss
Strayer J. stated (pp. 6510-6511): "... Normally a person who lends money when he is not in the business of money lending makes an investment unless there are unusual circumstances. ...
Decision summary
AB LLC and BD Holdings LLC v. Commrs. of South African Revenue Services, Case No. 13276, 15 May 2015, South Africa Tax Court -- summary under Article 7
See summary under Treaties – Art. 5. ...
TCC (summary)
Curragh Inc. v. The Queen, 94 DTC 1894, [1995] 1 CTC 2163 (TCC) -- summary under Subsection 216(4)
The Queen, 94 DTC 1894, [1995] 1 CTC 2163 (TCC)-- summary under Subsection 216(4) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(4) s. 216 does not relieve payor of liability In response to a submission that s. 216(4) seems to assume that a Canadian agent of a non-resident will receive rents or royalties on behalf of the non-resident free of withholding tax, Mogan TCJ. stated (p. 1898) that: "... if the Canadian agent is required to pay certain expenses and, his non-resident principal exercises the option in section 216 to pay Part I tax, there is nothing in section 216 which relieves the initial Canadian payor of his obligation to withhold and remit under subsection 215(1). ...
FCA (summary)
Gunn v. Canada, 2006 DTC 6544, 2006 FCA 281 -- summary under Resolving Ambiguity
Canada, 2006 DTC 6544, 2006 FCA 281-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity uncertainty from lack of explicitness resolved in taxpayer's favour Before going on to reject the interpretation in the Supreme Court of Canada decision in the Moldowan case that had the effect of reading the word "combination" out of s. 31(1), Sharlow J.A. noted (at p. 6556) that the objective that tax rules should be "consistent, predictable and fair" might be further undermined if the provisions of the Act "are applied on the basis of a judge-made rule that has no statutory foundation", and further stated (at para. 78) that "the Courts would do well to approach the combination question in section 31 with an eye on the case of Johns-Manville " where Estey J. stated that reasonable uncertainty resulting from lack of explicitness in the statute should be resolved in favour of the taxpayer. ...
Decision summary
Prestcost (Central) Ltd. v. Minister of Labour, [1969] 1 W.L.R. 89 (C.A.) -- summary under Comparison of Provisions
At 97: "... [T]he habit of a legal draftsman is to eschew synonyms. ...
TCC (summary)
Byrt v. MNR, 91 DTC 923, [1991] 2 CTC 2174 (TCC) -- summary under Estoppel
In finding that the taxpayer was later estopped from amending his pleadings to allege that he had resigned on January 24, 1985, Rip J. stated (pp. 932-933): "... ...