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TCC

Canadian Imperial Bank of Commerce v. The Queen, 2019 TCC 79, aff'd 2021 FCA 96

N Amer. a certificate or voucher presented as a gift and exchangeable for a specified value of goods, usu. at a specific store. 24   In the Ninth New Collegiate Dictionary, A Merriam-Webster, 1986, the definition of the phrase “gift certificate” is as follows: gift certificate n (1942): a certified statement entitling the recipient to select merchandise in the establishment of the issuer to the amount stated thereon 25   In ascertaining the import of section 181.2 of the Excise Tax Act, it is useful to keep in view the provisions of section 13 of the Official Languages Act, which reads: Any journal, record, Act of Parliament, instrument, document, rule, order, regulation, treaty, convention, agreement, notice, advertisement or other matter referred to in this Part that is made, enacted, printed, published or tabled simultaneously in both languages, and both language versions are equally authoritative. ...
TCC

Damis Properties Inc. v. The Queen, 2021 TCC 24

In this case, the transfer occurred in two steps and therefore it is necessary to identify the “precise point in time” [52] that the transfer occurred. [144] When interpreting legislation, “[i]t is assumed that the legislature is an accomplished user of language and has fully mastered the linguistic conventions through which meaning is communicated to an audience”. [53] It is therefore instructive to consider the grammatical meaning of the text used by the legislature. [145] The preamble uses the phrase “has transferred”. ...
TCC

Fiera Foods Company v. The King, 2023 TCC 140

For example, the definitions of “builder”, “charity”, “consumer”, “convention”, “debt security”, “financial service”, “money” and “office”. [184] See, generally, the presumptions regarding legislative drafting described in Ruth Sullivan, Statutory Interpretation, 3rd ed (Toronto: Irwin Law Inc, 2016), at page 129, particularly the third presumption. [185] See, for example, Walker v Ritchie, 2006 SCC 45 at paras 24 to 28. [186] Guindon at para 60. [187] Guindon at paragraph 60. ...
TCC

Blackmore v. The Queen, 2013 DTC 1213 [at at 1147], 2013 TCC 264, aff'd 2014 DTC 5123 [at 7316], 2014 FCA 210

In those cases, the phrase “beneficial owner” was referenced as it appeared in a particular tax convention. ...
TCC

Garber v. The Queen, 2014 DTC 1045 [at at 2812], 2014 TCC 1

Dec. 6, 1988 Convention Centre minutes: “Blond with glasses---Where is the money that our notes secure? ...
TCC

Grenon v. The Queen, 2021 TCC 30

(tax benefit) opération Sont assimilés à une opération une convention, un mécanisme ou un événement. ...

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