Section 161

Subsection 161(1) - General

Cases

Quinco Financial Inc. v. Canada, 2018 FCA 137

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 157 - Subsection 157(1) - Paragraph 157(1)(b) GAAR assessment for prior year was payable as at the balance-due date 166
Tax Topics - Income Tax Act - Section 245 - Subsection 245(2) taxpayers do not “apply” GAAR, but GAAR liability accrues before reassessment 260

Canada v. Zelinski, 2000 DTC 6001 (FCA)

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Words and Phrases
outstanding

Wargacki v. The Queen, 92 DTC 6336 (FCTD)

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The Queen v. Union Gas Ltd., 90 DTC 6659 (FCA)

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Rath v. The Queen, 82 DTC 6175, [1982] CTC 207 (FCA)

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Galway v. M.N.R., 74 DTC 6247, [1974] CTC 313 (FCA)

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See Also

Isah v. The Queen, 2018 TCC 28 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) TCC has jurisdiction to address incorrectly computed assessment interest 149

Quinco Financial Inc v. The Queen, 2016 TCC 190, aff'd 2018 FCA 137

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(2) taxpayers can be required to apply GAAR to themselves 135

J.K. Read Engineering Ltd. v. The Queen, 2014 DTC 1216 [at 3872], 2014 TCC 309

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Res Judicata weight of obiter depends on fulness of argument 77
Tax Topics - General Concepts - Stare Decisis weight of obiter depends on fullness of argument 77
Tax Topics - Income Tax Act - Section 245 - Subsection 245(7) GAAR applies to impose liability for abusive transactions from inception 212

Ford v. The Queen, 95 D.T.C 848 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(1) 94

Administrative Policy

91 C.R. - Q.61

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10 June 1991 T.I. (Tax Window, No. 4, p. 23, ¶1290)

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87 C.R. - Q.73

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Subsection 161(2) - Interest on instalments

Administrative Policy

93 C.R. - Q. 50

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86 C.R. - Q.66-69

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85 C.R. - Q.32

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 164 - Subsection 164(2) 28

Subsection 161(2.2) - Contra interest

Administrative Policy

87 C.R. - Q.74

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Subsection 161(4.1) - Limitation — corporations

See Also

I.G. (ROCKIES) Corp. v. The Queen, 2005 DTC 289, 2005 TCC 51 (Informal Procedure)

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Subsection 161(7) - Effect of carryback of loss, etc.

Cases

Connaught Laboratories Limited v. The Queen, 94 DTC 6697 (FCTD)

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See Also

Zandi v. The Queen, 2012 DTC 1246 [at 3707], 2012 TCC 259 (Informal Procedure)

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Administrative Policy

29 March 2011 External T.I. 2009-0351721E5 - Interest/ Penalty on Taxpayer-Requested Adjustment

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93 C.R. - Q. 49

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88 C.R. - F.Q.9

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86 C.R. - Q.70

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Paragraph 161(7)(b)

Administrative Policy

21 March 2018 External T.I. 2017-0736291E5 - Interest calculation - loss substitutions

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(b) net capital loss carried back from Year 3 replaces non-capital loss carryforward from Year 1 without interest cost 129