Evidence

Commentary

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Cases

Deputy Commissioner of Taxation v Rennie Produce (Aust) Pty Ltd (in liq), [2018] FCAFC 38

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Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) third-party documents obtained in commercial judicial proceedings were producible under a requirement issued by the tax authority 356

Olympia Trust Company v. Canada, 2015 FCA 279

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Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) RRSP trustee, not annuitant, was the "purchaser" 188
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) fictitious s. 104(2) trust is not the purchaser 112

Samaroo v. CRA, 2014 DTC 5096 [at 7137], 2014 BCSC 1349

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R. v. Eddy, 2014 DTC 5050 [at 6780], 2014 ABQB 164

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Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) reasonable limits on Crown obligations to disclose evidence to accused 253

R. v. McCartie, 2013 DTC 5136, 2013 BCPC 289

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Madison v. Canada, 2012 DTC 5072 [at 6935], 2012 FCA 80

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House v. Canada, 2011 DTC 5142 [at 6131], 2011 FCA 234

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Tax Topics - General Concepts - Onus 138

Syrek v. Canada, 2009 DTC 5767, 2009 FCA 53

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Canada v. General Motors of Canada Ltd., 2008 DTC 6381, 2008 FCA 142

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Canada v. 1524994 Ontario Limited, 2007 FCA 74

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply agreements respected for supply determination purposes 207
Tax Topics - General Concepts - Agency alleged principal lacked capacity to collect OHIP fees 252

Ventas Inc. v. Sunrise Senior Living Real Estate Investment Trust, 2007 ONCA 205

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R. v. Larsen, 2006 DTC 6574, 2005 BCSC 1867 (BCSC)

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Bernick v. Canada, 2004 DTC 6409, 2004 FCA 191

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Brown v. Canada, 2003 DTC 5298, 2003 FCA 192 (FCA)

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Lecours v. The Queen, 2003 DTC 5009, 2002 FCA 5 (FCA)

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Selmeci v. The Queen, 2002 DTC 7186, 2002 FCA 293 (FCA)

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Canada v. Canadian Helicopters Ltd., 2002 DTC 6805, 2002 FCA 30

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) indirect eligible use 133

Harris v. The Queen, 2002 DTC 149 (FCTD)

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Bell v. Canada, 2002 DTC 6780, 2002 FCA 7

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Trzop v. Canada, 2002 DTC 6728, 2001 FCA 380

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Vancouver Art Metal Works Ltd. v. The Queen, 2001 DTC 5337, 2001 FCT 265 (FCTD)

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James v. Canada, 2001 DTC 5075 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Audit Procedure 99
Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) vacating not a remedy for lack of due dispatch 84
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) no s. 56(2) inclusion to taxpayer if recipient of the transferred property had earned it rather than the taxpayer 314

Argus Holdings Ltd. v. The Queen, 2001 DTC 6681 (FCA)

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Backman v. The Queen, 99 DTC 5602 (FCA), aff'd 2001 DTC 5149 (SCC)

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Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Timmins v. The Queen, 96 DTC 6378 (FCTD)

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Tax Topics - Income Tax Act - Section 122.3 - Subsection 122.3(1) 169

Bertram v. The Queen, 96 DTC 6034 (FCA)

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MCA Television Ltd. v. The Queen, 94 DTC 6375 (FCTD)

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Sidhu v. MNR, 93 DTC 5453 (FCA)

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Tax Topics - Income Tax Act - Section 230 - Subsection 230(1) 75

The Queen v. Old HW-GW Ltd., 93 DTC 5199 (FCA)

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Tax Topics - Statutory Interpretation - Context 37

Urichuk v. The Queen, 93 DTC 5120 (FCA)

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R. v. Castelli, 92 DTC 6556 (Ont. Ct. GD)

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Stowe-Woodward Inc. v. The Queen, 92 DTC 6149 (FCTD)

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Bowes v. The Queen, 91 D.T.C 5310 (FCTD)

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The Queen v. Betterest Vinyl Manufacturing Ltd., [1990] 2 CTC 292 (BCCA)

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Wil Mechanical Ltd. v. The Queen, 90 DTC 6475 (FCTD)

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Border Chemical Co. Ltd. v. The Queen, 87 DTC 5391, [1987] 2 CTC 183 (FCTD)

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The Queen v. Gorjup, 87 DTC 5348, [1987] 2 CTC 129 (FCTD)

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Phyllis Moore v. The Queen, 87 DTC 5217 (FCTD)

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Moore v. The Queen, 87 DTC 5215 (FCA)

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Magilb Development Corp. Ltd. v. The Queen, 87 DTC 5012, [1987] 1 CTC 66 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate tentative overtures for subdivision did not effect a change in use 103
Tax Topics - Income Tax Act - Section 9 - Computation of Profit preliminary overtures for approval of housing development of farm did not convert to inventory 204

The Queen v. Capitol Life Insurance Co., 86 DTC 6164, [1986] 1 CTC 388 (FCA)

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R. v. Marcoux, 85 DTC 5453, [1985] 2 CTC 254 (Alta. Prov. Ct.)

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Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 3rd party seizure invalid 45

Spencer v. R., 85 DTC 5446, [1985] 2 CTC 310 (SCC)

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Armstrong v. The Queen, 85 DTC 5396 (FCTD)

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Burri v. The Queen, 85 DTC 5287, [1985] 2 CTC 42 (FCTD)

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Tax Topics - Income Tax Act - Section 129 - Subsection 129(4) - Canadian Investment Income apartment rentals were not from an active business 80

W. Rudolph Construction Ltd. v. The Queen, 84 DTC 6454, [1984] CTC 457 (FCTD)

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Frankel v. The Queen, 84 DTC 6220, [1984] CTC 259 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 222 66

Lipsey v. MNR, 84 DTC 6192, [1984] CTC 208 (FCTD)

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Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) 77

Stephens v. The Queen, 84 DTC 6169 (FCTD)

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Greiner v. The Queen, 84 DTC 6073, [1984] CTC 92 (FCA)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition "otherwise disposed of" includes extinguishment on surrender 79
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) 199

Bouchard v. The Queen, 83 DTC 5193, [1983] CTC 173 (FCTD)

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Riviera Hotel Co. Ltd. v. The Queen, 82 DTC 6045, [1982] CTC 30 (FCTD)

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Carruthers v. The Queen, 82 DTC 6009, [1982] CTC 5 (FCTD)

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Don Fell Ltd. v. The Queen, 81 DTC 5282, [1981] CTC 363 (FCTD)

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Honeywood Ltd. v. The Queen, 81 DTC 5066, [1981] CTC 38 (FCTD)

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Tax Topics - Income Tax Act - Section 256 - Subsection 256(2.1) 51

Sandhu v. The Queen, 80 DTC 6097, [1980] CTC 158 (FCTD)

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Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) partner carries on partnership business 15
Tax Topics - Income Tax Act - Section 96 60

Vanguard Trailers Ltd. v. The Queen, 80 DTC 6001, [1980] CTC 42 (FCTD)

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The Queen, v. Leclerc, 79 DTC 5440, [1979] CTC 527 (FCTD)

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Tax Topics - Income Tax Act - Section 68 69

Hummel Corp. of Quebec Ltd. v. The Queen, 79 DTC 5426, [1979] CTC 483 (FCTD)

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Pepsi-Cola Canada Ltd. v. The Queen, 79 DTC 5387, [1979] CTC 454 (FCA)

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Gahrns v. The Queen, 78 DTC 6436, [1978] CTC 651 (FCTD)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 27

Atinco Paper Products Ltd. v. The Queen, 78 DTC 6387, [1978] CTC 566 (FCA)

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Wardean Drilling Co. Ltd. v. M.N.R., 78 DTC 6202, [1978] CTC 270 (FCTD)

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Dobell v. The Queen, 77 DTC 5316, [1977] CTC 458 (FCTD)

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Darke v. MNR, 76 DTC 6468, [1976] CTC 734 (FCTD)

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The Queen v. Esskay Farms Ltd., 76 DTC 6010, [1976] CTC 24 (FCTD)

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Rosenblat v. The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)

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David v. The Queen, 75 DTC 5136, [1975] CTC 197 (FCTD)

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Grant v. The Queen, 74 DTC 6252, [1974] CTC 332 (FCTD)

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The Queen v. Kuhl, 74 DTC 6024, [1973] CTC 846 (FCTD)

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MNR v. Beaupré Estate, 73 DTC 5255, [1973] CTC 316 (FCTD)

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Weinberger v. MNR, 64 DTC 5060 (Ex Ct)

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Sinnott News Company Ltd. v. The Minister of National Revenue, 56 DTC 1047, [1956] CTC 81, [1956] S.C.R. 433

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Tax Topics - Income Tax Act - Section 9 - Timing 183

Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82

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R. v. Snider, 54 DTC 1129, [1954] CTC 255 (SCC)

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Salter v. MNR, [1946] Ex CR 634, 2 DTC 918

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See Also

Ellison v Sandini Pty Ltd, [2018] FCAFC 44

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership family court order requiring the transfer of a portion of a larger bloc of shares likely did not result in a change in their beneficial ownership as the shares likely were not fungible 973
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition family court order did not effect a change in beneficial ownership of a larger bloc of shares held by the original owner (and in any event, the order named the wrong person) 744
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) - Paragraph 73(1)(b) subjective belief of parties that family court orders were efficacious did establish that a share transfer to a spouse occurred “because of” them 407

Rowntree v Commissioner of Taxation, [2018] FCA 182

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Other locations for this summary
Tax Topics - General Concepts - Evidence contract must be evinced by documents or conduct
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) loan or other contract can only be achieved explicitly or through being evinced by conduct 396

CIT Group Securities (Canada) Inc. v. The Queen, 2016 TCC 163, 2017 TCC 86

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Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(l) - Subparagraph 95(2)(l)(iii) regulated Barbados subsidiary which invested in corporate debt qualified under the s. 95(2)(l) exclusion for foreign banks 698
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Bank no requirement to be regulated as a bank 239

Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent 371
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) s. 142(1)(d) only applies to a supply exclusively re real property 594
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service payment of condo operating expenses was a service 201
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of covering all time share operating costs 164
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) GST collectible based on invoicing times 77
Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) objecting to quantum was sufficient particularity 169
Tax Topics - General Concepts - Ownership beneficial owner did not transfer property risk 177

Okoroze v. The Queen, 2015 DTC 1107 [at 627], 2015 TCC 64

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McCarthy v. The Queen, 2016 TCC 45

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Chaudhry v. The Queen, 2016 DTC 1030 [at 2721], 2016 TCC 28 (Informal Procedure)

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Advocate Gen. for Scotland v. Murray Group Holdings Ltd., [2015] CSIH 77, [2015] BTC 36 (Ct. of Ses. (Inner House, 2nd)), aff'd sub nomine RFC 2012 Plc (formerly The Rangers Football Club Plc) v Advocate General for Scotland (Scotland) [2017] UKSC 45

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) income derived from service is assessable even where agreed to be redirected to 3rd party 321
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) Scottish and English trust concepts had similar practical effect 84

Staltari v. The Queen, 2015 DTC 1130 [at 818], 2015 TCC 123

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business no business where no business organization 155
Tax Topics - Income Tax Act - Section 38 - Paragraph 38(a.2) land donated in order to achieve tax benefit was still a gift to a qualified donee 119
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) exclusion of gains that are ordinary income 139
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate secondary intention to develop land irrelevant if land donated instead 484

George Weston Limited v. The Queen, 2015 TCC 42

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange cross-currency swap was a hedge notwithstanding no intention to sell underlying indirect U.S. asset 426

Invesco Canada Ltd. v. The Queen, 2014 TCC 375

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration management fee distributions to large MFT unitholders 155
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) discounted management fees charged by manager to MFTs not grossed up by MFT distributions of the discounts to large unitholders 308

Agnico-Eagle Mines Limited v. The Queen, 2015 DTC 1008 [at 43], 2014 TCC 324, aff'd 2016 FCA 130

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) U.S. dollar principal of a convertible debenture should be considered on conversion to have been settled at the historical exchange rate when the conversion price was set 508
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) U.S. dollar principal of a convertible debenture should be considered on conversion to have been settled at the historical exchange rate when the conversion price was set

Daimsis v. The Queen, 2014 DTC 1118 [at 3273], 2014 TCC 118 (Informal Procedure)

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Henco Industries Limited v. The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192

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Tax Topics - General Concepts - Fair Market Value - Land deference to taxpayer's figure within appraiser's range of values 105
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) compensation received in course of business but not in course of earning income 184
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital payment to withdraw from business was not an eligible capital amount 138
Tax Topics - Income Tax Act - Section 23 - Subsection 23(1) land ceased to be inventory through sterilization rather than business cessation 176
Tax Topics - Income Tax Act - Section 3 compensation payment for destroyed business was non-taxable 163
Tax Topics - Income Tax Act - Section 9 - Compensation Payments compensation payment for destroyed business was non-taxable 163

Bolton Steel Tube Co. Ltd. v. The Queen, 2014 DTC 1102 [at 3202], 2014 TCC 94

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) reassessment to add fictitious income was void 312
Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) s. 169(3) reassessment cannot increase quantum of previous assessment 202

Vine Estate v. The Queen, 2014 DTC 1088 [at 3130], 2014 TCC 64

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Tax Topics - General Concepts - Fair Market Value - Land rent-controlled apartment 96

Roszko v. The Queen, 2014 DTC 1083 [at 3099], 2014 TCC 59

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit contractual payments derived from fraud v. contract itself is a fraud 123

Cameco Corporation v. The Queen, 2014 TCC 45

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) appeals from superceded reassessments were nullities 54
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege basis for claim not disclosed 113

McKesson Canada Corporation v. The Queen, 2014 DTC 1040 [at 2723], 2013 TCC 404

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Tax Topics - General Concepts - Purpose/Intention tax purpose v. commercial result 78
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) terms adjusted within framework of transaction chosen by taxpayer 894
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(4) advocacy 3rd-party report not read by taxpayer 149
Tax Topics - Treaties - Income Tax Conventions - Article 9 5-year limitation did not apply to secondary Part XIII assessment 190

Lee v. The Queen, 2013 DTC 1227 [at 1248], 2013 TCC 289

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Pièces automobiles Lecavalier Inc. v. The Queen, 2014 DTC 1126 [at 3319], 2013 TCC 310

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) debt-paydown transactions were avoidance transactions 236
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) avoidance of debt forgiveness rules was abusive 247
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) debt-paydown transactions effected in contemplation of sale transaction were part of same series as the sales transactions 216

Harvey v. The Queen, 2013 TCC 298

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) guilty plea is prima facie proof of income from tax evasion 101
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose deduction based on authorized use 107

Last v. The Queen, 2012 DTC 1290 [at 3895], 2012 TCC 352

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Raposo v. The Queen, 2013 DTC 1216 [at 1199], 2013 TCC 265

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) guilty plea prima facie proof of income from fraud 177

River Hills Ranch Ltd. v. The Queen, 2013 DTC 1200 [at 1064], 2013 TCC 248

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Tax Topics - Income Tax Act - Section 9 - Compensation Payments payments styled as herd expense reimbursements in substance were capital receipts for destruction of business and were proceeds of the related agreements 274

Rahman v. The Queen, 2012 DTC 1270 [at 3799], 2012 TCC 320 (Informal Procedure)

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Kelly v. The Queen, 2012 DTC 1109 [at 3055], 2012 TCC 66

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Hafizy v. The Queen, 2012 DTC 1093 [at 2943], 2012 TCC 56, aff'd 2014 FCA 109

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Zaki v. The Queen, 2011 DTC 1004 [at 18], 2010 TCC 606 (Informal Procedure)

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On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at 4243], 2010 TCC 475

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Cirone v. The Queen, 2010 DTC 1103 [at 3034], 2010 TCC 137

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Suzanne Sterling-Ross v. The Queen, 2009 DTC 1892, 2009 TCC 525 (Informal Procedure)

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Ollivierre v. The Queen, 2009 DTC 1796, 2009 TCC 490 (Informal Procedure)

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Witt v. The Queen, 2008 DTC 4322, 2008 TCC 407

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Klaboe v. The Queen, 2007 TCC 239

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Corpor-Air Inc. v. The Queen, 2007 DTC 841, 2006 TCC 75

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Avotus Corporation v. The Queen, 2007 DTC 215, 2006 TCC 505

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Benjamin v. The Queen, 2006 DTC 2265, 2006 TCC 69 (Informal Procedure)

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Yoon v. The Queen, 2005 DTC 1109, 2005 TCC 366

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Shahsavar v. The Queen, 2005 DTC 523, 2005 TCC 184

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Redrupp v. The Queen, 2004 DTC 3320, 2004 TCC 640

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Morley v. The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171

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VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732

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Hewlett Packard (Canada) Ltd. v. The Queen, 2003 DTC 1324 (TCC), rev'd 2004 DTC 6498, 2004 FCA 240

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Chomica v. The Queen, 2003 DTC 535 (TCC)

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Petro-Canada v. The Queen, 2003 DTC 94 (TCC), aff'd supra.

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Aikman v. The Queen, 2002 DTC 6874 (FCA)

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Imperial Oil Ltd. v. The Queen, 2002 DTC 1954 (TCC)

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Hunter v. The Queen, 2001 DTC 907 (TCC) (Informal Procedure)

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Mathew v. The Queen, 2001 DTC 742 (TCC)

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Davidson v. The Queen, 99 DTC 933 (TCC)

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Promex Group Inc. v. The Queen, 98 DTC 1588 (TCC)

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Mihelakos v. The Queen, 97 DTC 1450 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 98 - Subsection 98(2) 71

Telecomsyst Services Inc. v. The Queen, 97 DTC 684 (TCC)

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Lay v. The Queen, 95 DTC 272 (TCC)

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Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) 101

Kalousdian v. The Queen, 94 DTC 1722 (TCC)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.4) 167

Kamsel Leasing Inc. v. MNR, 93 DTC 250 (TCC)

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C&E Commissioners v. Battersea Leisure Ltd., [1992] BTC 5011 (Q.B.)

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United Color and Chemicals Ltd. v. MNR, 92 DTC 1259 (TCC)

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Samra v. MNR, 92 DTC 1008 (TCC)

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Savoidakis v. MNR, 91 DTC 1463 (TCC)

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Docherty v. MNR, 91 DTC 537 (TCC)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) 77

Village Inn Hotel Ltd. v. MNR, 91 DTC 145 (TCC)

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Pallan v. MNR, 90 DTC 1102 (TCC)

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Essex County Council v. Ellam, [1989] BTC 133 (CA)

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Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221

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Schouten v. MNR, 63 DTC 397 (TAB)

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Warsh & Co. Ltd. v. MNR, 62 DTC 247 (TAB)

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Doughty v. Commissioner of Taxes, [1927] AC 327 (PC)

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Administrative Policy

IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farm Land and Inherited Land and Conversion from Real Estate from Capital Property to Inventory and Vice Versa"

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Articles

Lucie Lamarre ACJ, Isida Ranxi, "Taxpayer Rights and Voluntary Compliance: The Example of the Canadian Judiciary", Tax Notes International, 3 October 2016, p. 61

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Amir Pichhadze, "Can, and Should, the Parol Evidence Rule Be Invoked by or against the Canadian Tax Authorities in Tax Litigation? Lessons from US Jurisprudence", Bulletin for International Taxation, September 2013, p. 474

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The Sedona Canada Principles Addressing Electronic Discovery, (January 2008) (thesedonaconference.org), Principle 2

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Michele Anderson, "The Heresay Exception for Business Records: Why Section 30 of the Canada Evidence Act matters", Tax Litigation, Vol. XI, No. 4, 2003, p. 714.

Quigley, "Dealing with Expert Evidence in Tax Cases", 1993 Canadian Tax Journal, No. 6, p. 1071.

Perell, "The Problems of Without Prejudice", 71 Canadian Bar Review, June 1992, p. 223.