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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. ...

Sarraf considered that a court appeal was a mere continuation of proceedings which had been commenced against the corporation by the Minister’s assessment – but Dawson JA found that Sarraf had failed to consider that the current appeal procedures were quite different from the Income War Tax Act procedures considered in a yet earlier decision. ...

Leonati, [1996] 3 S.C.R. 458 … at paragraph 51). ...

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Canada, 2016 FCA 304-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract pointless to determine whether an instrument is debt for purposes of whole Act The Federal Court of Appeal dismissed the Barejo appeal – but on the grounds that the Rule 58 question posed to the Tax Court was whether the “notes” in question were debts for purposes of the Act rather than for purposes of s. 94.1 thereof. ...

Canada, 2016 FCA 299-- summary under Section 8.1 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 8.1 Tax Court can review validity of contract in reviewing assessment Before indicating that it was unnecessary to pass on whether it was beyond the competence of the Tax Court to declare that options were invalid under Quebec law, Noël CJ stated (at para. 42, TaxInterpretations translation): [T]he role of the TCC, when confronted with an argument based on nullity in the context of an appeal under the ITA, cannot be assimilated to that of a Superior Court which has the power to “declare” a contract to be a nullity for all purposes pursuant to section 33, 35 and 142 of the Code of Civil Procedure … (see in comparison Markou v. ...

Green, 2017 FCA 107-- summary under Paragraph 111(1)(e) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(e) upper-tier LP not required to compute income and therefore not subject to s. 111(1)(e) CRA considered that business losses incurred by lower tier partnerships (the PSLPs) were deemed to be limited partnership losses of an upper-tier LP (MLP) – which meant that they were effectively trapped in MLP given that s. 111 (and, thus, the ability to deduct limited partnership losses under s. 111(1)(e)) was only available to a taxpayer and not to a partnership such as MLP. ...

. … Seeking “a sensible, practical and common sense result” is quite different from dispassionately and objectively examining the text, context and purpose of the legislation in issue; the latter turns on the nature of the legislation while the former depends on the nature of the judge. ...