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The Queen, 92 DTC 6305, [1992] 2 CTC 1 (FCTD)-- summary under Treaties Summary Under Tax Topics- Statutory Interpretation- Treaties "... ...

Since, at the time of signing the royalty agreement the licensee's estimated net sales for the following three years were only $1,500,000, only $75,000 (= 5% x $1,500,000) was includible in the taxpayer's income under s. 12(1)(g). ...

Minister of National Revenue, 97 DTC 5126, [1997] 2 CTC 30 (FCA)-- summary under Purpose/Intention Summary Under Tax Topics- General Concepts- Purpose/Intention Robertson J.A. stated (at p. 5135) after discussing jurisprudence on paragraph 20(1)(c): "... ...

Taylor, 84 DTC 6234, [1984] CTC 244 (FCTD)-- summary under Expressio Unius est Exclusio Alterius Summary Under Tax Topics- Statutory Interpretation- Expressio Unius est Exclusio Alterius " Prima facie the same words in different parts of the same Statute should be given the same meaning unless there is a clear reason for not doing so. ...

The Queen, 80 DTC 6314, [1980] CTC 386 (FCTD)-- summary under Subsection 74.1(1) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(1) Under a court-approved variation of trust, the plaintiff forewent his vested right to receive a ½ share of the income of a trust, and a discretionary trust was created whose beneficiaries included his wife. ...

The Queen, 82 DTC 6085, [1982] CTC 151 (FCTD)-- summary under Section 222 Summary Under Tax Topics- Income Tax Act- Section 222 Where two individuals, who carried on a construction business in partnership with each other as well as through 9 incorporated companies, knew that payments being made by them to the Receiver General respecting arrears of taxes of the partnership and the companies were being credited to the companies ' accounts, they were later precluded from arguing that the payments should have been applied by the Department instead to reduce the amount of the debt owing by the partnership to the Receiver General. ...

., doubted that a judge would ever be in a position to direct the issuance of a notice of assessment because "to issue mandamus the Court must be satisfied that all the conditions have been met for the exercise of the power, and that in the circumstances the official in question has no discretionary power to delay or to refuse taking the step which is sought to be ordered by mandamus ". ...

The Queen, 94 DTC 6280, [1994] 2 CTC 64 (FCTD)-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) channels expense deductions Before going on to find that the taxpayer had a reasonable expectation of profit with respect to one of his businesses for only one of the taxation years in question, Joyal J. stated (p. 6281) that: "... section 4 of the Act, in establishing the 'sourcing' or 'matching' principle in the determination of any income or loss, limits considerably the more imaginative ways in which a taxpayer may lump all his income from all sources and deduct all his expenses from these sources and consolidate his return accordingly. ...

., 2019 FC 506, aff'd 2020 FCA 85-- summary under Subsection 289(3) Summary Under Tax Topics- Excise Tax Act- Section 289- Subsection 289(3) requirement to show all customers with significant purchases Campbell J authorized a requirement by the Minister for Roofmart to disclose the particulars of all its customers who in any of the past 4 ½ years had made purchases of construction materials from Roofmart in excess of an annualized total of $20,000. ...

. … Just because the documents are not part of the evidentiary record does not mean that they are not part of the Court record and, it should be recalled, it is the documents in the Court record that are subject to the open court principle. ... The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...