Cases
Tedesco v. Canada, 2019 FCA 235
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Act - Section 16.2 - Subsection 16.2(2) | discontinuance did not imply adjudication of appealed issue | 148 |
Canada v. ACI Properties Ltd., 2014 DTC 5036 [at 6718], 2014 FCA 45
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 174 - Subsection 174(1) | Minister need not have uncertainty in her views | 147 |
| Tax Topics - Income Tax Act - Section 174 - Subsection 174(3) | 3rd party added to existing appeal under s. 174(3)(b) | 197 |
Canada (National Revenue) v. RBC Life Insurance Company, 2013 FCA 50
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(6) | 297 |
Special Risks Holdings Inc. v. The Queen, 84 DTC 6054, [1984] CTC 71 (FCTD), aff'd 84 DTC 6215, [1984] CTC 563 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 483(4) | 81 | |
| Tax Topics - Income Tax Act - Section 231.2 | 40 |
Medicine Hat Greenhouse Ltd. and German v. R., 79 DTC 5091, [1980] CTC 114 (Alta. C.A.)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 24 | |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(4) | 63 |
See Also
Stewart v. The Queen, 2018 TCC 75, rev'd on TCCA s. 16.2/no abuse of process grounds 2019 FCA 235
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.7) | partners were not necessarily precluded under the s. 152(1.7) “binding” rule from arguing that a partnership determination of loss was statute-barred | 207 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 16.2 - Subsection 16.2(2) | discontinuance has equivalent effect to dismissal by court itself | 203 |
Construction S.Y.L. Tremblay Inc. v. Agence du revenu du Québec, 2018 QCCA 552
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Stare Decisis | Court of Quebec not bound by Tax Court decisions/stare decisis does not preclude relitigation where unfairness would otherwise result | 208 |
| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(c) - Subparagraph 3(c)(iv) | failure of invoices to describe the supplies could not be remedied by testimony | 397 |
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) | failure of invoices to describe supply was in itself sufficient to deny credit | 168 |
McIntyre v. The Queen, 2014 DTC 1116 [at 3258], 2014 TCC 111
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| Tax Topics - General Concepts - Res Judicata | criminal convictions establish only a floor on tax liability; plea bargains aren't dispositive | 240 |
Congiu v. The Queen, 2013 TCC 271, aff'd 2014 FCA 73
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Res Judicata | not res judicata where two different government litigants | 266 |
| Tax Topics - General Concepts - Stare Decisis | 266 | |
| Tax Topics - General Concepts - Judicial Comity | judicial comity re Quebec decision | 221 |
Houda International Inc. v. The Queen, [2011] GSTC 8, 2010 TCC 622
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 305 - Subsection 305(5) - Paragraph 305(5)(b) | relitigation of same appeal extension ruled on in Quebec would be abuse of process and contrary to judicial comity | 221 |
| Tax Topics - General Concepts - Judicial Comity | relitigation of same appeal extension ruled on in Quebec would be contrary to judicial comity | 125 |
Golden v. The Queen, 2008 DTC 3363, 2008 TCC 173
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Estoppel | 179 | |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 44 |