Cases
Canada (National Revenue) v. ConocoPhillips Canada Resources Corp., 2014 FCA 297, rev'g 2013 FC 1192
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Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.5 | appeal to Tax Court required for decision of CRA to treat a Notice of Objection as invalid | 228 |
Conocophillips Canada Resources Corp. v. Canada (National Revenue), 2014 DTC 5014 [at 6598], 2013 FC 1192, rev'd supra
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Clearwater Seafoods Holding Trust v. Canada, 2013 DTC 5132 [at 6218], 2013 FCA 180
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Tax Topics - Income Tax Act - Section 88.1 - Subsection 88.1(2) | 285 |
460354 Ontario Inc. v. The Queen, 92 DTC 6534 (FCTD)
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Tax Topics - Other Legislation/Constitution - Ontario - Business Corporations Act - Section 242 | 36 |
Attorney General of Canada v. Bowen, 91 DTC 5594 (FCA)
Nova Ban-Corp Ltd. v. Tottrup, 89 DTC 5489 (FCTD)
Mackay Construction Ltd. v. The Queen, 89 DTC 5097 (FCTD)
The Queen v. Gary Bowl Ltd., 74 DTC 6401, [1974] C.T.C 457 (FCA)
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Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 341 [Judgment on Admissions] | 95 | |
Tax Topics - Income Tax Act - Section 172 - Subsection 172(1) | 83 |
Okalta Oils Ltd. v. Minister of National Revenue, 55 DTC 1176, [1955] CTC 271, [1955] S.C.R. 824
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Words and Phrases
assessmentSee Also
Davis v. The Queen, 2015 DTC 1105 [at 621], 2015 TCC 79 (Informal Procedure)
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Nottawasaga Inn Ltd. v. The Queen, 2014 DTC 1021 [at 2628], 2013 TCC 377 (Informal Procedure)
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Words and Phrases
nil assessmentLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | 314 |
SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181
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Tax Topics - General Concepts - Agency | consent of counsel binding | 104 |
Tax Topics - General Concepts - Onus | 79 | |
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | 50 | |
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 117 |
Mcfadyen v. The Queen, 2008 DTC 4513, 2008 TCC 441
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Tax Topics - General Concepts - Res Judicata | 144 |
Graham v. The Queen, 92 DTC 1012 (TCC)
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Tax Topics - General Concepts - Onus | 143 | |
Tax Topics - Income Tax Act - Section 244 - Subsection 244(10) | 61 |
Hill v. MNR, 91 DTC 1094 (TCC)
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 135 |
Lornport Investments Limited v. Her Majesty The Queen and Project Construction Limited v. Her Majesty The Queen, 91 DTC 5044, [1991] 1 CTC 57 (FCTD)
Bowen v. MNR, 90 DTC 1625 (TCC)
Lornex Mining Corp. Ltd. v. MNR, 88 DTC 6399, [1988] 2 CTC 195 (FCTD)
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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 36 |
The Queen v. Bowater Mersey Paper Co. Ltd., 87 DTC 5382, [1987] 2 CTC 159 (FCA)
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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 129 |
Gibbs v. MNR, 84 D.TC. 6418, [1984] CTC 434 (FCTD)
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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 37 |
MNR v. Parsons and Flemming, 84 DTC 6345, [1984] CTC 352 (FCA)
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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 48 |
Millers Credit Jewellers Ltd. v. The Queen, 84 DTC 6205, [1984] CTC 218 (FCTD)
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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 106 | |
Tax Topics - Income Tax Act - Section 68 | 62 |
Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA)
MacIsaac v. The Queen, 83 DTC 5258, [1983] CTC 213 (FCTD)
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Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 86 |
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 8
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Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) | time stamping of items received | 91 |
S4-F7-C1 - Amalgamations of Canadian Corporations
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Subsection 169(1) - Appeal
Cases
Savics v. Canada, 2021 FCA 56
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Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) | reference in a settlement agreement to CRA making consequential adjustments was not limited to those made under s. 152(4.3) | 405 |
Tax Topics - Income Tax Act - Section 152 - Subsection 152(5) | s. 152(5) permits the restoration of an initial assessment of income that had been previously reversed by reassessment | 547 |
1455257 Ontario Inc. v. Canada, 2016 FCA 100
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Tax Topics - Other Legislation/Constitution - Ontario - Business Corporations Act - Section 242 | dissolved corporation cannot launch appeal/voluntarily dissolved corp cannot be revived by Companie Branch | 264 |
Tax Topics - General Concepts - Stare Decisis | prior decisons overruled only if manifestly wrong | 89 |
Canada v. Doiron, 2012 DTC 5103 [at 7081], 2012 FCA 71
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 311 |
Canada v. Quigley, 2009 DTC 6206, 2009 FCA 287
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Canada v. General Motors of Canada Limited, [2009] GSTC 64, 2009 FCA 114
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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | services for pension plans represented compensation costs relating to taxable sales | 133 |
Canada v. Interior Savings Credit Union, 2007 DTC 5342, 2007 FCA 151
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Bormann v. Canada, 2006 DTC 6147, 2006 FCA 83
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398722 Alberta Ltd. v. Canada, [2000] FCJ No. 644 (CA)
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity | 160 |
MNR v. Minden, 62 DTC 1044 (Ex Ct)
Cole v. Canada (Attorney General), 2005 DTC 5667, 2005 FC 1445
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Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) | 153 |
Transcanada Pipelines Ltd. v. The Queen, 2001 DTC 5626, 2001 FCA 314
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(7) | 198 |
See Also
Lilyfield Development Inc. v. The Queen, 2020 TCC 16
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Locations of other summaries | Wordcount | |
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Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Act - Section 21 | appeal is not launched until Notice of Appeal is filed | 224 |
102751 Canada Inc. v. Agence du revenu du Québec, 2019 QCCQ 7378, aff'd 2021 QCCA 605
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages | legal fees incurred to recover misappropriated funds were not capital expenditures | 369 |
Pietrovito v. The Queen, 2017 TCC 119
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Tax Topics - Income Tax Act - Section 167 - Subsection 167(5) - Paragraph 167(5)(a) | time period not suspended where taxpayer reasonably believed appeal had been filed | 357 |
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 54 | failure to appeal 2nd taxation year not curable through amendment | 81 |
Shreedhar v. The Queen, 2016 TCC 254 (Informal Procedure)
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | assessment of nil tax and $2 of interest could be objected to | 134 |
Beggs v. The Queen, 2016 TCC 11 (Informal Procedure)
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Words and Phrases
assessmentLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) | refusal to grant Reg. 105 waiver not an assessment/remedy in FC | 84 |
Izumi v. The Queen, 2014 DTC 1114 [at 3254], 2014 TCC 108
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Pylatuke v. The Queen, 2014 DTC 1019 [at 2620], 2013 TCC 364
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Cameco Corporation v. The Queen, 2014 TCC 45
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Tax Topics - General Concepts - Evidence | proportionality principle | 202 |
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | basis for claim not disclosed | 119 |
Clearwater Seafoods Holdings Trust v. The Queen, 2012 DTC 1177 [at 3447], 2012 TCC 186, rev'd supra
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McIntosh v. The Queen, 2011 DTC 1116 [at 625], 2011 TCC 147
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Uddin v. The Queen, 2009 DTC 1331, 2009 TCC 471 (Informal Procedure)
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Khan v. The Queen, 2009 DTC 804, 2009 TCC 248 (Informal Procedure)
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Locations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Onus | 41 |
Interior Savings Credit Union v. The Queen, 2006 DTC 3351, 2006 TCC 411
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Parent v. The Queen, 2003 DTC 1002, 2003 TCC 509
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Imperial Oil Ltd. v. The Queen, 2003 DTC 179, 2003 TCC 46, aff'd 2003 FCA 289
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Locations of other summaries | Wordcount | |
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Tax Topics - Statutory Interpretation - Ordinary Meaning | 84 |
Wells v. The Queen, [2001] 4 CTC 2950 (TCC)
Administrative Policy
3 June 2014 Internal T.I. 2013-0489471I7 - Subsection 171(1)
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.3) | no power to reassess following order to vacate or vary | 107 |
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | no power to reassess following order to vacate or vary | 111 |
Subsection 169(2.1) - Limitation on appeals by large corporations
Cases
Devon Canada Corporation v. Canada, 2015 FCA 214
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11) | large corporations can appeal new issues which were rejected by CRA Appeals, and perhaps may raise new issues within 1 year of Objection | 103 |
Bakorp Management Ltd. v. Canada, 2014 DTC 5063 [at 6870], 2014 FCA 104
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11) | new timing argument raised on appeal | 348 |
See Also
Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172, aff'd 2018 FCA 124
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 | 417 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | investment dealer fees re advisability of making hostile takeover were fully deductible | 529 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) | legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales | 182 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) | takeover bid circular costs did not qualify | 102 |
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations | 365 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | failure to advance evidence showing allocation of fees to share consideration | 139 |
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | expenses incurred in butterfly spin-off recognized as disposition expenses | 63 |
Tax Topics - Statutory Interpretation - French and English Version | finding common meaning of 2 versions of s. 20(1)(bb) | 108 |
Ford Motor Company of Canada Limited v. The Queen, 2015 TCC 39
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Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) | issues raised in Objection were understandable in light of previous materials provided to CRA | 278 |
Devon Canada Corporation v. The Queen, 2014 DTC 1192 [at 3727], 2014 TCC 255, rev'd 2015 FCA 214
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Canada v. Telus Communications (Edmonton) Inc., 2005 FCA 159
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Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) | due diligence defence not raised | 174 |
Subsection 169(2.2) - Waived issues
Cases
See Also
Savics v. The Queen, 2019 TCC 71, aff'd 2021 FCA 56
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) | a settlement agreement referring to partnership loss allocations included partnership gains allocations | 540 |
Administrative Policy
AD-19-01 Audit Agreement and Waiver of Objection Rights Guidelines 2019-02-19
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 460 |
Subsection 169(3) - Disposition of appeal on consent
Cases
Savics v. Canada, 2021 FCA 56
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Words and Phrases
consequential adjustmentLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(5) | s. 152(5) permits the restoration of an initial assessment of income that had been previously reversed by reassessment | 547 |
Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | an assessment exists until it has been nullified by a reassessment | 379 |
Canada v. CBS Canada Holdings Co., 2020 FCA 4
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Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) - Paragraph 171(1)(b) | Tax Court order could contemplate increased taxes for 1 taxation year in implementing settlement agreement | 247 |
University Hill Holdings Inc. (Formerly 589918 B.C. Ltd.) v. Canada, 2017 FCA 232
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | a settlement agreement agreeing as to round percentages of expenses that were unreasonable accorded with Galway | 317 |
See Also
984274 Alberta Inc. v. The Queen, 2019 TCC 85, rev'd 2020 FCA 125
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) | reassessment made pursuant to late waiver was void | 34 |
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | reassessment made pursuant to late waiver could not be cured by s. 152(8) | 47 |
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) | invalid reassessment could not establish a refund amount | 263 |
Tax Topics - Income Tax Act - Section 160.1 - Subsection 160.1(1) | refund made pursuant to a void reassessment was not made pursuant to the Act (and also was not a “refund” on ordinary principles) so that s. 160.1(1) unavailable | 488 |
Savics v. The Queen, 2019 TCC 71, aff'd 2021 FCA 56
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Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.2) | waiver does not preclude appeal where settlement agreement improperly implemented | 245 |
CBS Canada Holdings Co. v. The Queen, 2018 TCC 188, aff'd 2020 FCA 4
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | settlement agreement was grounded in reality | 150 |
Granofsky v. The Queen, 2016 TCC 181, aff'd 2017 FCA 119
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Bolton Steel Tube Co. Ltd. v. The Queen, 2014 DTC 1102 [at 3202], 2014 TCC 94
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Locations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Evidence | terms of agreement established with regard to "factual matrix" | 116 |
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | reassessment to add fictitious income was void | 336 |
Administrative Policy
27 February 2020 Report of the Quebec Ombudsman entitled "“So that taxpayers’ rights are upheld in payment arrangement proposals with Revenu Québec”
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Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(2) | Quebec Ombudsperson criticizes the ARQ for not following the Galway principle in settlement agreements | 482 |