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See summary under s. 237.1(1) – tax shelter. ...

The Queen, 2003 DTC 5324 (FCTD)-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) The taxpayer's application for relief based on his being " de facto bankrupt" was rejected by a CCRA officer who did not have appropriate delegated authority. ...

General Provisions In indicating that to the extent that there is any overlap between ss.15(1)(c) and 7(1), the latter provision should prevail, Bowman TCJ. stated (p. 138): "... where a choice must be made between two taxing provisions that might conceivably apply to require an inclusion in income, a specific provision should prevail over a general one, on the footing that Parliament must be taken to have intended that the specific provisions would regulate the particular type of transaction. ...

The Queen, 95 DTC 5477, [1995] 2 CTC 316 (FCA)-- summary under Context Summary Under Tax Topics- Statutory Interpretation- Context After finding that the 40 kilometer distance referred to in s. 62(1) of the Act should be measured on the basis of the shortest normal route to the traveling public, Marceau J.A. stated (at p. 5479): "... by applying the straight line rule to the calculation of the distance referred to in subsection 62(1) of the Act, the Tax Court of Canada has interpreted the word without regard to the context and, in so doing, had committed an error of law.... ...

International Commercial Bank Ltd. (1978), 52 TC 242 (HL)-- summary under Accounting Principles Summary Under Tax Topics- Income Tax Act- Section 9- Accounting Principles In finding that discounts on bills should be taken into income on the disposition of the bills rather than on a straight-line basis, as was done for accounting purposes, Lord Fraser stated (p. 272): "... the Crown, relied on the general rule that the principles of commercial accounting should normally prevail. ...

& T. "were controlled by the same... group of persons" (i.e., Saunder and Thornborrow) for purposes of s. 39(4)(b) of the pre-1972 Act, Cattanach J. stated (p. 5098): "In my view the word 'controlled' in section 39(4)(b) contemplates and includes such a relationship as, in fact, brings about a control by virtue of majority voting power, no matter how that result is effected, that is, either directly or indirectly. ...

The registrant's business usage was only 54%, which was clearly not " all or substantially all" of the use of the vehicle. ...

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. ...

The Queen, 2016 DTC 1018 [at 2629], 2016 TCC 10-- summary under Paragraph 111(1)(e) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(e) limited partnership losses flow through a 2-tier LP structure Paris J found that the business losses of a limited partnership allocated to an upper-tier partnership in excess of its at-risk amount continue to be business losses in its hands, so that such losses can, in turn be allocated to the partners in the upper-tier partnership – so that, if the at-risk amount rules apply, it is only to restrict the losses that are allocated to the partners in the upper-tier partnership. ...

The chapeau of section 2 “Prescription Drugs and Biologicals” does not contemplate any and all drugs, rather it contemplates drugs that may be obtained through a recognized channel – a prescription. ...