Subsection 221(1) - Regulations
Cases
Pictou v. Canada, 2003 FCA 9
The appellants, who were status Indians, were unsuccessful in a submission that treaties concluded in 1760 and 1761 between the Mi'kmaq and...
Paragraph 221(1)(d)
Cases
James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614
It was stated that if the Minister thinks that traders in the commodities futures market generally are not reporting their transactions properly...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 | 94 | |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | 30 |
Paragraph 221(1)(f)
Cases
Doyle v. MNR, 89 DTC 5483, [1989] 2 CTC 270 (FCTD)
Reed, J. stated: "I have no doubt that the kind of authority described in s. 225.1(5) is such that it would be reasonable, indeed almost...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | 125 | |
| Tax Topics - Income Tax Act - Section 225.1 - Subsection 225.1(5) | 54 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer | 31 |
James Richardson & Sons, Ltd. v. MNR, 82 DTC 6204, [1982] CTC 239 (FCA), rev'd supra.
A s. 231(3) demand for information that was signed by the "Director-Taxation Winnipeg District Office", was held to be valid in light of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 | 95 |
Les Magasins Continental Ltée v. The Queen, [1982] 2 F.C. 351, 81 DTC 5175, [1981] CTC 428 (C.A.)
Subsection 900(1) of the Regulations authorizes the Assistant Deputy Minister not only to exercise the power of the Minister to issue a direction...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 247 - Old - Subsection Old 247(2) | 82 | |
| Tax Topics - Other Legislation/Constitution - Federal - Official Languages Act - Section 13 | 15 |
See Also
Air Canada v. Turner, [1984] 6 WWR 346 (BCSC)
Subsection 9(2) of the Gasoline Tax Act (B.C.) provided that an assessment was to be made by an "authorized officer". A Notice of Assessment...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 96 |
Paragraph 221(1)(h)
Cases
The Queen v. Sun Life Assurance Co. of Canada, 80 DTC 6333, [1980] CTC 418 (FCA)
The tax imposed by s. 212(1) "must be paid 'on every amount' irrespective of its capital or income nature". An argument that in order to be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(h) | 44 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit | 86 |
Subsection 221(2) - Effect
Cases
Intertan Canada Ltd. v. MNR, 96 DTC 6522, [1996] 3 CTC 257 (FCTD)
S.221(2), which overrides s. 9(1) of the Statutory Instruments Act, permitted s. 22(9) of SOR/85-696 to have retroactive effect.