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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. ...

Nadon J.A. stated (at para. 12): "... a plain reading of both the French and English text of paragraph 8(1)(h.1) of the Act makes it clear that the words 'motor vehicle expenses incurred for travelling in the course of the office...' necessarily require that these expenses be incurred by the taxpayer while performing the duties of his office. ...

Thomson & Associates Ltd. to make a survey of pulp and newsprint pricing discounts and commissions, who obtained the relevant information from members of the industry on the assurance that such information would be protected by the strictest confidentiality. ...

Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose It was noted that the question to be answered under s. 18(1)(a) (unlike S.6(1)(a) of the Income War Tax Act, 1948) is whether the outlay or expense "was incurred for the purpose of gaining or earning income- not ' the income' (which implies a specific source of income) and not 'wholly, exclusively and necessarily...' therefrom, but simply 'for the purpose of...'". ...

General Provisions In finding that paragraph 13(21)(d) rather than 79(c) governed the determination of the proceeds of disposition of a property, Linden J.A. stated (at p. 6576): "... this is not a case where, because of a conflict, the Court must choose to apply a specific provision over a general one in accordance with that well-known principle of statutory interpretation; there is no conflict here. ...