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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. ...

The Queen, 2015 DTC 1119 [at 749], 2015 TCC 109 (Informal Procedure)-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 122.6- Shared-Custody Parent- Paragraph (b) 33-49 split was not “equal or near-equal” basis The taxpayer took care of her two step-sons for approximately 33% of the hours in a given two-week period, while her spouse's ex-wife took care of them for approximately 49% of the time – the balance being taken up by school. ...

. …. The portion of the lot that he sold together with the house was attributable to the use of the house and was reasonably necessary for its use and enjoyment as a place of residence for individuals. ...

Summary Under Tax Topics- Statutory Interpretation- Hansard, explanatory notes, etc. purpose inferred in part from Legislative Assembly statement of Minister The Court inferred from a response (quoted at para. 21) to an MLA question given by the Minister of Energy in the Alberta legislature- that there was an intention to create “level playing field” between municipally-owned power companies and taxable competitors – that it was contrary to the purpose of a legislative rule requiring such otherwise-exempt companies to make payments in lieu of taxes, to be able to “shelter” their earnings by paying junk-bond interest rates on financing from their exempt parents. ...

After noting that retention of the client files was professionally recommended, Bocock J stated that deductibility was “consistent with the notion of unavoidable expenses necessarily expended in future years referable to previous income contemplated in … Poulin, Raegele and Langille.” ...

The Queen, 2019 TCC 5 (Informal Procedure)-- summary under Paragraph 125(3)(b) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(3)- Paragraph 125(3)(b) SBD denied because no agreement made In confirming the correctness of a reassessment of a corporation (Newgate) denying it the small business deduction, D’Auray J stated (at paras 36-37): … At trial, it was shown that the effect of the underlying reassessment was to disallow Newgate’s small business deduction… because Newgate and its associated corporation, 807 BC Ltd., made inconsistent filings…. ...

., 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. ...

These requirements are essentially the same as in the common law provinces …. ...