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Instead, the words "it may reasonably be considered" placed a substantial onus on the taxpayer to produce some explanation which is objectively reasonable that none of the purposes was to alter the value of a shareholder's interest". ...

Such an allegation could be asserted by her in the Federal Court when the Minister attempted to recover the sums he considered to be payable. ...

Such an allegation could be asserted by her in the Federal Court when the Minister attempted to recover the sums he considered to be payable. ...

New Brunswick [1972] S.C.R. 471 indicated that subsequent amendments might be considered as part of the legislative history bearing on the construction on the amended statute, this did not mean, in light of s. 45(3) of the Interpretation Act, that subsequent amendments could themselves serve as a declaration concerning the previous state of the law. ...

., 96 DTC 6065, [1996] 2 CTC 55 (FCA)-- summary under Subsection 1204(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 1204- Subsection 1204(1) Although the taxpayer (which was a participant in the Syncrude oil sands project) went on to achieve partial success on other grounds, Pratte J.A. first found that the trial judge erred in finding that in order for the taxpayer to be considered to be "producing" petroleum, it was necessary that there be a prospect of the Syncrude project being profitable in the near future, and also found that the oil producing activities of the project commenced when the mining of the oil sands deposits commenced rather than when the first barrel of synthetic crude was produced. ...

Canada (Attorney General), 2004 DTC 6276, 2004 FCA 125-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) The Court rejected the taxpayer's submission that as a councillor with the County of Newell in Alberta, his place of business was the whole of the applicable County Division and found that an allowance received by him for travel between his home and the place of Council meetings was taxable on the basis of jurisprudence establishing that travel expenses incurred by a taxpayer in travelling to and from his home to his place of work are considered personal expenses. ...

A business, to be considered inactive, need not be in an "absolute state of suspension", and it is irrelevant that the business activities were carried on by another party on the taxpayer's behalf, rather than by the taxpayer itself. ...

VI-I-2(d) "was intended to apply to certain drugs that could be legally sold to a consumer,” as contrasted to illegal sales, Rennie JA stated (at para. 21): Headings may be considered as part of the search for parliamentary intention, particularly in the case where the language is obscure, as it is in this case. ...

Canada, 2020 FCA 90-- summary under Section 14 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 14 marginal notes may be considered as part of the interpretive process Before going on to accord a restrictive interpretation to s. 149(1)(d.5) based on the wording of the marginal note to s. 149(1)(c), which contained similar wording, Mactavish JA stated (at para. 54): [I]n accordance with section 14 of the Interpretation Act … marginal notes do not form part of a statute, and are only inserted for ease of reference. ...

CAMECO Corporation, 2020 FCA 112-- summary under Marginal Notes Summary Under Tax Topics- Statutory Interpretation- Marginal Notes marginal note referred to as indication of provision’s thrust After referencing authorities on the relevance of headings including Supreme Court quotation of Driedger that headings "should be considered part of the legislation and should be read and relied on like any other contextual feature" (para. 58), Webb JA stated (at para. 60) that the “Transfer Pricing Adjustment” “heading” (i.e., marginal note) to s. 247(2) was indicative that it was primarily a pricing-adjustment rather than a recharacterization rule. ...