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., 93 DTC 5199, [1993] 1 CTC 363 (FCA)-- summary under Context Summary Under Tax Topics- Statutory Interpretation- Context MacGuigan J.A. applied the "words-in-total-context approach" in finding that because Puerto Rico was a country for purposes of Regulations 5907(10)(b) and (c), it also should be considered to be a country for purposes of Regulation 5907(10)(a). ...

The Queen, 85 DTC 5004, [1984] CTC 661 (FCTD)-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law It was found that since income tax law "must be interpreted consistently throughout Canada", the conferral of a benefit by deed of sale should not be regarded as a gift for the purpose of s. 69(1)(c) of the Act even though it would probably be considered as a gift in Quebec law. ...

The Queen, 2013 DTC 1218 [at at 1210], 2013 TCC 266 (Informal Procedure)-- summary under Subsection 118.5(1) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(1) piano lessons Favreau J stated (at para. 22): I do not think that a one-hour piano lesson per week is sufficient for the Appellant's son to be considered as being enrolled at an university, college, or other educational institution providing courses at a post-secondary level. ...

The Queen, 86 DTC 6122, [1986] 2 CTC 69 (FCA)-- summary under Paragraph Old 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- Old- Paragraph Old 247(2)(a) Under s. 247(2)(a), the Minister must determine whether those who were responsible for the separate existence of the corporations had, as their sole purpose, the intention that the business of the corporations be carried out in what they considered to be the most effective manner. ...

General Provisions Although a lump sum received by the taxpayer might be considered to come within the more general terms of "remuneration" under s. 6(3)(b) in addition to constituting a retiring allowance, the rule generalia specialibus non derogant was applied to find that a retiring allowance should not be included in remuneration under s. 6(3)(b). ...

National Bank of Canada, 2004 DTC 6527, 2004 FCA 92-- summary under Subsection 227(4.1) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(4.1) The respondents, who seized and sold movable property secured by movable hypothecs, were required to comply with a demand made upon them to pay over amounts equal to the unpaid source deductions at the time of such sale given that they should be considered to be secured creditors rather than third party purchasers. ...

., 98 DTC 6004, [1998] 1 CTC 99 (FCA)-- summary under Purpose/Intention Summary Under Tax Topics- General Concepts- Purpose/Intention In light of the additional word in s. 15(1.1) referring to "it may reasonably be considered", the Tax Court Judge had erred in finding that the relevant purpose must be the conscious intent of the taxpayer. ...

[A]ctivities may be contracted out by the taxpayer [as was the case here] and the latter will still be considered as engaging in a farming operation. ...

" It was further stated that the activities of the taxpayer would be considered by the general public to constitute "farming. ...

., 99 DTC 5602, [1999] 4 CTC 177 (FCA), aff'd 2001 DTC 5149 (SCC)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence In the absence of convincing evidence on Texas law, the Court looked to the Alberta Partnership Act to determine whether the taxpayer, by virtue of being assigned a partnership interest, could be considered to have become a partner in a Texas partnership notwithstanding that he was not carrying on business in common with the other supposed partners. ...