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Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD)-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law In finding that lease agreements were in reality purchase agreements, Decary, J. stated: "fiscal law is an accessory system, which applies only to the effects produced by contracts. ...

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Section 12 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 12 An assessment that erroneously referred to the taxation year of the taxpayer as ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8) of the Income Tax Act, after a brief reference was made to s. 12 of the Interpretation Act. ...

Customs & Excise Commissioners v. Automobile Association, [1974] 1 WLR 1447 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Upon paying for membership in the Automobile Association, a member was considered to be paying not for the mere privilege of membership but for the benefits that a member received under his contract with the Automobile Association and, accordingly, the subscription price is apportionable among those services and facilities received by each member. ...

James Richardson & Sons, Ltd. v. MNR, 82 DTC 6204, [1982] CTC 239 (FCA), rev'd supra.-- summary under Paragraph 221(1)(f) Summary Under Tax Topics- Income Tax Act- Section 221- Subsection 221(1)- Paragraph 221(1)(f) A s. 231(3) demand for information that was signed by the "Director-Taxation Winnipeg District Office", was held to be valid in light of Regulation 900(2)(b), which provides that such an official may exercise the authority of the Minister under s. 231(3). ...

Block Research & Development (1981) Corp. v. MNR, 87 DTC 5137, [1987] 1 CTC 253 (FCTD)-- summary under Subsection 223(1) Summary Under Tax Topics- Income Tax Act- Section 223- Subsection 223(1) "[T]he liability to pay tax under the Income Tax Act arises before any assessment has been made" and "under the Act, the Minister is entitled to assess at any time and is not bound to wait for the end of a fiscal year. ...

Smith, Kline & French Laboratories Ltd. v. A.G. Can. (1987), 12 F.T.R. 81-- summary under Interpretation Bulletins, etc. ...

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)-- summary under Public Policy Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Public Policy Fines paid by the taxpayer, a trucking company, for violations of highway weight restriction laws "resulted from the day to day operation of its transport business and were paid as a necessary expense," and accordingly were deductible. ...

Burnet, Duckworth & Palmer, [1993] WWR 374, 8 BLR (2d) 280 (Alta. ...

B & J Music Ltd., 83 DTC 5074, [1983] CTC 50 (FCA)-- summary under Subparagraph 125(6)(b)(ii) [repealed] Summary Under Tax Topics- Income Tax Act- Section 125- Subparagraph 125(6)(b)(ii) [repealed] Since the cumulative deduction account is stated to include "the corporation's taxable income" rather than "the corporation's taxable income while a Canadian-controlled private corporation", it includes taxable income earned by a corporation prior to becoming a Canadian-controlled private corporation. ...

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Paragraph 221(1)(d) Summary Under Tax Topics- Income Tax Act- Section 221- Subsection 221(1)- Paragraph 221(1)(d) It was stated that if the Minister thinks that traders in the commodities futures market generally are not reporting their transactions properly for income tax purposes, then he can obtain a regulation under S.221(1)(d) requiring all such traders to file returns of their transactions, rather than making an impermissible demand for information under S.231(3). ...