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" Furthermore, the rebuttable presumption articulated in Marconi – that income earned by corporations acting consistently with their objects is income from a business – was not helpful here as "presumably corporations will act within their objects [and] the legislative scheme expressly contemplates a corporation earning income from property. ...

BG1(1) of the Income Tax Act 2004 (NZ) provided that a tax avoidance arrangement (defined to include an arrangement that has “tax avoidance as its purpose or effect … [or] as 1 of its purposes or effects … if the purpose or effect is not merely incidental”) was void as against the Commissioner. ...

., Ms Ellison] “because of a court order under the Family Law Act 1975 ” (Australia). ... In essentially returning to and concluding on the beneficial ownership issue, she stated (at para. 164): [T]he orders vested statutory rights and a beneficial interest of some kind in Ms Ellison but … I do not consider that interest can be characterised as beneficial ownership …. ... None of those matters arise on construction of the orders. … In short, on their own terns, the orders have no operation and cannot be enforced. ...

The PSPPA stated that bcIMC “ is not liable for taxation except as the government is liable for taxation.” ... However, Weatherill J found that the Agreements were legislatively binding on bcIMC, stating (at para 166): … [I]n my view there is specific legislation that creates the obligation on bcIMC to pay the Tax. Section 16 of the PSPPA states that bcIMC “…is not liable for taxation except as the government is liable for taxation ”. ...

He stated (at paras. 76-77): The purpose of the Act … is to reduce GHG [green-house gas] emissions on a nation-wide basis. ... After noting (at para. 80) that “there is today a greater appreciation that environmental pollution can transcend national and international boundaries and it is no longer thought of as a purely local concern,” and in finding that the charges were within the national concerns branch of the federal peace, order and good government (POGG) power, he stated (at paras. 113-114, 133): Counsel for the Attorney General of British Columbia proposes a useful summary of the “singleness, distinctiveness and indivisibility” requirements: (1) singleness requires that the matter be characterized as specifically and narrowly as possible, at the lowest level of abstraction consistent with the fundamental purpose and effect of the statute; (2) distinctiveness requires that the matter be one beyond the practical or legal capacity of the provinces because of the constitutional limitation on their jurisdiction to matters “in the Province”; and (3) indivisibility means that the matter must not be an aggregate of matters within provincial competence, but must have its own integrity – this normally occurs where the failure of one province to take action primarily affects extra-provincial interests, including the interests of other provinces, other countries and Indigenous and treaty rights. ... Establishing minimum national standards to reduce GHG emissions meets these requirements. … Confining Canada’s jurisdiction to the establishment of minimum national standards to reduce GHG emissions does not result in a massive transfer of broad swaths of provincial jurisdiction to Canada, as Ontario claims. ...

Inland Revenue Commissioner, [1991] 4 All E.R. 443 (PC)-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 In refusing to follow the decision in James Richardson & Sons Ltd. in a similar fact situation, Lord Templeman noted that in that case "the court held that the express power in s. 221, a power which had not been exercised, limited the general power conferred by s. 231" (p. 448). ...

The assessed amount can change from time to time by virtue of judicial decisions or new assessments: Terra Nova Properties … [1967] 2 Ex. ...

In dismissing an application to the Court to declare that the trust was valid, Nixon J adverted to the principle in Addison & Leyen Ltd v Canada, 2007 SCC 33 (CanLII), [2007] 2 S.C.R. 793, at para. 11 that "Judicial review should not be used to develop a new form of incidental litigation designed to circumvent the system of tax appeals established by Parliament and the jurisdiction of the Tax Court," and stated (at para. 66): The only dispute with respect to the validity of the Trust is with the CRA in relation to the payment of tax. ...

(as she then was) in S & K Processors Ltd. v. Campbell Avenue Herring Producers Ltd. (1983), 35 C.P.C. 146 (S.C.) in saying that "waiver of privilege as to part of a communication, will be held to be waiver as to the entire communication". ...

In this regard, the Court stated (at para. 139): In the current edition of Bowstead, namely Watts P and Reynolds FMB, Bowstead & Reynolds on Agency (20th ed, 2014), the relevant ‘rules’ are set out in Arts 94 and 95. ...