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In finding that the U.S. corporation was associated with each Canadian corporation (with the result that each Canadian corporation was associated with the other two Canadian corporations under the pre-1972 version of s. 256(2)), Jackett C.J. noted (p. 5037) that the rules in s. 39(4) of the pre-1972 Act applied "for the purposes of this section", that those rules determined the amount of tax payable under Part I by associated corporations and that it followed "that section 39(4) has no application to determine whether two corporations are associated unless they are both subject to income tax under Part I of the Income Tax Act ". ...

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Before affirming a finding of the Tax Court Judge that the taxpayer, in substance, had thereby been deducting a reserve under s. 20(1)(m), McDonald J.A. stated (para. 20): "... ...

., 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): "... ...

In giving relatively little weight to possible inferences to be drawn from Budget Papers, MacGuigan J.A. stated (at p. 6132 and at 6134): "... ...

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. ...

See summary under s. 118.1(1) – total charitable gift. ...

See summary under s. 118.1(1) – total charitable gift. ...

Convention is the gain which is subject to tax " (p. 5454) the proration of gain under paragraph 9 of Article XIII, was required to be calculated by reference to the period of time that the property in question (a cottage owned by the taxpayer and his previously-deceased wife since 1967) had been held subsequent to December 31, 1971 (the date on which the capital gains became subject to tax) rather than during the whole period of ownership. ...

. … Structures that lead to repetition, over-elaboration of arguments, block quotations, and rhetorical flourishes make submissions diffuse. ...