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

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

The Queen, 96 DTC 6034 (FCA)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Before finding that an apparently doctored document that had been provided by one of the taxpayers to Revenue Canada in a meeting with them was not covered by the privilege attaching to settlement negotiations, Hugessen J.A. stated (at p. 6039): "... ...

The Queen, 2006 DTC 3548, 2006 TCC 480-- summary under Subsection 227.1(1) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(1) Before finding that the taxpayer was a de facto director of a corporation that had never been organized on the basis that the taxpayer along with the other major shareholder were the directing minds of the corporation, Paris J. stated (at pp. 3551): "... where a corporation operates without having been properly organized and the only director of record plays no part in running the corporation, those persons who take it upon themselves to direct the affairs of the company may be held to be de facto directors, whether or not they have explicitly represented themselves as directors to any third party. ...

MNR, 61 DTC 1099, [1961] CTC 134 (Ex Ct)-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) "rent" can be for personalty In finding that payments made by the taxpayer to its U.S. parent for the use by it of equipment in its Canadian business represented "rent, royalty or a similar payment" under s. 106(1)(d) of the pre-1972 Act, Thurlow J. stated (at p. 1105): "... ...

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. ...

., 97 DTC 5089, [1997] 1 S.C.R. 411-- summary under Expressio Unius est Exclusio Alterius Summary Under Tax Topics- Statutory Interpretation- Expressio Unius est Exclusio Alterius After finding that s. 28(1) of the Personal Property Security Act was inconsistent with a broad interpretation of a licence of a debtor to sell without the proceeds being subject to the respondent's security interests, Iacobucci J. stated (at p. 5091): "... this is an appropriate case for the invocation of the maxim expressio unius est exclusio alterius. ...

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. ...

. … …[T]he standard must be at least as high as gross negligence under s. 163(2)…. ...