Search - 教育部《义务教育课程方案（2003年版）》

The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business The taxpayer was not considered to be engaged in a business of making loans by virtue of the Canadian corporation of which it was a sole shareholder declaring a dividend and a stated capital reduction to be paid by way of the issuance of demand promissory notes. ...

The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing A dividend was income to the taxpayer in the year the dividend was declared in light of the "underlying assumption in the Income Tax Act that income from business or property will be determined by the accrual method of accounting". ...

Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 SCR 94-- summary under French and English Version Summary Under Tax Topics- Statutory Interpretation- French and English Version The Court concluded (at p. 5192) in considering the interpretation of section 32 of the Crown Liability and Proceedings Act (Canada) that "the English version best reflects the intent of the legislature". ...

Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 SCR 94-- summary under Prior Cases Summary Under Tax Topics- Statutory Interpretation- Prior Cases The Court applied (at p. 5192) the principle that "in determining the legislative intent behind the current wording in s. 32, it is useful to examine the judicial interpretation given to the provision that came before it. ...

Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 SCR 94-- summary under Redundancy/reading in words Summary Under Tax Topics- Statutory Interpretation- Redundancy/reading in words The Court rejected a submission of the Crown that had the effect of adding the words "at any time" to the provision in question. ...

The Queen, 2003 DTC 179, 2003 TCC 46, aff'd 2003 FCA 289-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning An argument of the Crown that a taxpayer is not entitled to object to an assessment based on its own return of income or an assessment that does not result in an adverse adjustment, was rejected. ...

Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 SCR 94-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity After referring to dictionary definitions of the word "poursuite", the Court stated (at p. 5191): It would therefore be difficult to conclude definitively that 'poursuite' is more restrictive than 'proceedings' and that this is determinative in the context of s. 32. ...

Blouin, 2003 DTC 5420, 2003 SCC 31, [2003] 1 SCR 666-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) Deschamps J. ...

Blouin, 2003 DTC 5420, 2003 SCC 31, [2003] 1 SCR 666-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law Deschamps J. stated (in dissenting reasons with which the majority did not disagree) (at p. 5430) that: "It is settled law that the legislature may assign tax consequences to a juridical act that are different from the consequences that follow under the rules of the civil law. ...

Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 SCR 94-- summary under Section 32 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Crown Liability and Proceedings Act- Section 32 Section 32 of the Crown Liability and Proceedings Act applied to prohibit the taking of collection action against the taxpayer six years after a cause of action against him arose, namely, the expiry of the 90-day period after the mailing of a notice of assessment to him. ...