Charter (Constitution Act, 1982)

Cases

Canada Without Poverty v. AG Canada, 2018 ONSC 4147

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Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(6.2) ss. 149.1(6.2)(a) and (b) are of no force and effect 353

Preamble

Cases

Huet v. The Queen, 95 DTC 5008 (FCTD)

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Vanguard Coatings and Chemicals Ltd. v. The Queen, 88 DTC 6374, [1988] 2 CTC 178 (FCA)

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Section 1

Cases

Solvent Petroleum Extraction Inc. v. MNR, 88 DTC 6224, [1988] 1 CTC 325 (FCTD), aff'd 89 DTC 5381 (FCA)

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See Also

McFadyen v. The Queen, 2000 DTC 2473 (TCC), aff'd 2003 DTC 5015 (FCA)

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Tax Topics - Treaties - Income Tax Conventions - Article 4 139

Paragraph 2(a)

Cases

Schachtschneider v. The Queen, 93 DTC 5298 (FCA)

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O'Sullivan v. The Queen, 91 DTC 5491 (FCTD)

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Prior v. The Queen, 88 DTC 6207, [1988] 1 CTC 241 (FCTD), aff'd 89 DTC 5503 (FCA)

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Paragraph 2(b)

Cases

Canada (Attorney General) v. Chad, 2018 FC 319

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Tax Topics - Other Legislation/Constitution - Federal - Canada Evidence Act - Section 37 CRA had to show and justify why it had to redact materials in order to not shed light on its audit methodology 423
Tax Topics - Income Tax Act - Section 231.6 - Subsection 231.6(2) Minister required to provide material in support of requirement 207

OPSEU v. National Citizens' Coalition, 90 DTC 6326 (Ont CA)

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R. v. Reid, [1988] 3 WWR 162 (Alta. C.A.)

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See Also

Pakzad v. The Queen, 2017 TCC 83 (Informal Procedure)

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Section 6

Cases

Yates v. The Queen, 2001 DTC 761 (TCC) (Informal Procedure)

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Section 7

Cases

Canada (National Revenue) v. Stankovic, 2018 FC 462

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Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) a taxpayer with an unreported Swiss bank account was not yet under criminal investigation 402
Tax Topics - General Concepts - Stare Decisis Quebec CA decision relied upon 32
Tax Topics - Income Tax Act - Section 231.7 - Subsection 231.7(1) mere suspicion of criminal activity did not oust s. 231.1 188

Samaroo v. Canada Revenue Agency, 2018 BCSC 324

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Tax Topics - General Concepts - Malicious Prosecution CRA dominated prosecution and knowingly misstated evidence 577
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Subsection 24(1) malicious prosecution in breach of s. Charter rights gave rise to Charter s. 24 damages in the alternative 143

Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, [2015] 1 S.C.R. 401

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Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 Charter protection against statutory erosion of privilege extends beyond a criminal context and includes client identity 355
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege Charter protection against statutory erosion of privilege extends beyond a criminal context and includes client identity 355

R. v. Kennedy, 2003 DTC 5413 (BCSC)

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Kaulius v. Canada, 2003 FCA 371, 2003 DTC 5644 (FCA), aff'd 2005 DTC 5538, 2005 SCC 55

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Tax Topics - General Concepts - Stare Decisis 102

R. v. Jarvis (2000), 193 DLR (4th) 656 (Alta CA)

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The Queen v. Gregory, 2000 DTC 6561 (FCA)

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Del Zotto v. The Queen, 97 DTC 5145 (FCTD)

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Tax Topics - Income Tax Act - Section 231.4 105

Hokhold v. The Queen, 93 DTC 5339 (FCTD)

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Clow v. The Queen, 92 DTC 6155 (FCTD)

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Tax Topics - Income Tax Act - Section 167 - Subsection 167(5) 19

Chester v. The Queen, 92 DTC 6166 (Man QB)

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Tyler v. MNR, 91 DTC 5022 (FCA)

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462657 Ontario Ltd. v. MNR, 89 DTC 5445 (FCTD)

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R. v. McCall, 85 DTC 5448, [1986] 1 CTC 23 (B.C. Prov. Ct.)

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Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 evidence inadmissible 24

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

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Tax Topics - General Concepts - Evidence 41

See Also

Leeper v. The Queen, 2015 DTC 1115 [at 733], 2015 TCC 82 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 118 - 118(2) - 118(2)(n) supplements, vitamins and herbs not eligible 46
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Subsection 15(1) non-creditability of natural cancer remedies not discriminatory 47

Section 8

Cases

Bauer v. Canada, 2018 FCA 62

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Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) CRA could constitutionally issue a s. 231.2 requirement to the taxpayer’s bank during a Special Investigations review 349

Brochu v. Agence du revenu du Québec, 2018 QCCS 722

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Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) a requirement to provide documents “immediately” was contrary to the Quebec equivalent of s. 231.2 484

Revcon Oilfield Constructions Incorporated v. Canada (National Revenue), 2017 FCA 22

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Tax Topics - Income Tax Act - Section 231.7 - Subsection 231.7(1) s. 231.7 continues to apply to non-lawyers 164

Uber Canada Inc. v. ARQ, 2016 QCCS 2158, aff'd 2016 QCCA 1303

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Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1.1) Uber drivers, as operators of “taxi” businesses, likely were required to register for QST 268
Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) it was reasonable for ARQ on a search to seize smart phones and laptops to make subsequent complete copies 416
Tax Topics - General Concepts - Illegality Uber drivers' breach of provincial registration statute did not justify their failure to register for QST purposes 226

Canada (Attorney General) v. Chambre des notaires du Québec, 2016 SCC 20, [2016] 1 S.C.R. 336

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Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) s. 231.2 does not apply to lawyers 123
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege exception for accounting records is unconstituional 134

Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, [2015] 1 S.C.R. 401

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Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 state cannot impose duties that undermine lawyer's duty of commitment to client's cause 248
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege Charter protection against statutory erosion of privilege extends beyond a criminal context and includes client identity 355

Piersanti v. Canada, 2014 FCA 243

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Tax Topics - Excise Tax Act - Section 289 propriety of evidence collection for criminal purposes is irrelevant to its admissibility in tax appeals 151
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) propriety of evidence collection for criminal purposes is irrelevant to its admissibility in tax appeals 151

Canada (National Revenue) v. Jakabfy, 2013 DTC 5128 [at 6198], 2013 FC 706

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The Queen v. Anderson, 2003 DTC 5483 (Sask CA)

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R. v. Dial Drugstores Ltd., 2003 DTC 5206 (Ont. Sup. Ct. J.)

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Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) 82

Kligman v. MNR, 2003 DTC 5100 (FCTD)

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Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) 87

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. Canada (Attorney General); R. v. Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 S.C.R. 209

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Tax Topics - Income Tax Act - Section 232 - Subsection 232(3) unconstitutional lack of privilege safeguards 200

The Queen v. Norwood, 2001 DTC 5111 (FCA)

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Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) 132

R. v. Jarvis (2000), 193 DLR (4th) 657 (Alta CA)

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Gernhart v. The Queen, 99 DTC 5749 (FCA)

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Tax Topics - Income Tax Act - Section 176 - Subsection 176(1) 37

R. v. Anderson, 99 DTC 5536 (Sask. P. Ct.)

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The Queen v. Warawa, 98 DTC 6471 (Alta. Q.B.)

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The Queen v. Kloster, 98 DTC 6258 (Prov. Ct. B.C.)

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Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) 50

Deloitte & Touche Inc., Trustee of Vancouver Trademark Inc. v. Attorney General of Canada, 97 DTC 5520 (FCTD)

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Del Zotto v. The Queen, 97 DTC 5328 (FCA)

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Tax Topics - Income Tax Act - Section 231.4 - Subsection 231.4(1) 19

R. v. Harris, 95 DTC 5653 (BCSC)

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Tax Topics - Income Tax Act - Section 231.2 93

Baron v. Canada, 93 DTC 5018, [1993] 1 S.C.R. 416

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Carlini Bros. Body Shop Ltd. v. The Queen, 92 DTC 6543 (Ont. Ct. J. - G.D.)

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McKinlay Transport Ltd. v. The Queen, 90 DTC 6243 (SCC)

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Kourtessis and Hellenic Import-Export Co. Ltd. v. MNR, 89 DTC 5464 (BCCA), aff'd 93 DTC 5137, [1993] 2 S.C.R. 53

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Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) 55

Solvent Petroleum Extraction Inc. v. The Queen, 89 DTC 5381 (FCA)

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Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) 87

F.K. Clayton Group Ltd. v. MNR, 88 DTC 6202, [1988] 1 CTC 353 (FCA)

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Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) 56

R. v. James; Dzagic v. R., 86 DTC 6432, [1986] 2 CTC 288 (Ont.C.A.), briefly aff'd 88 DTC 6273, [1988] 1 S.C.R. 669

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

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Tax Topics - General Concepts - Evidence 94

R. v. McCall, 85 DTC 5448, [1986] 1 CTC 23 (B.C. Prov. Ct.)

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Stephens v. The Queen, 85 DTC 5359, [1985] 2 CTC 149 (FCTD)

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Lewis v. M.N.R., 84 DTC 6550, [1984] CTC 642 (FCTD)

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MNR v. Kruger Inc., 84 DTC 6478, [1984] CTC 506 (FCA)

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Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) 131

Hunter v. Southam Inc., 84 DTC 6467 (SCC)

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Re Charron, 84 DTC 6241, [1984] CTC 237 (FCTD)

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The Queen v. Roth, 84 DTC 6181, [1984] CTC 185 (SCO)

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McLeod v. MNR, 83 DTC 5112, [1983] CTC 168 (FCTD)

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See Also

R. v. BT Céramiques Inc., 2017 QCCS 4262

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Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) mere suspicion of tax (GST) evasion insufficient to render a penal investigation 151

9162-4676 Québec Inc. (known as Trimax) v. ARQ, 2016 QCCA 962

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Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) law firm search invalidated for failure of the information to demonstrate that there was no alternative for getting the documents 401

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

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Re Belgoma Transportation Ltd. (1985), 51 OR (2d) 509 (Ont CA)

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Statement of Claim

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Section 11

Cases

Guindon v. Canada, 2015 SCC 41, [2015] 3 S.C.R. 3

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Tax Topics - Income Tax Act - Section 163.2 - Subsection 163.2(1) - Culpable Conduct conduct must be at least as bad as gross negligence 102
Tax Topics - Income Tax Act - Section 163.2 - Subsection 163.2(4) penalty not criminal so that s. 11 Charter protection not engaged 330

Canada v. Guindon, 2013 DTC 5133 [at 6117], 2013 FCA 153, aff'd supra

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Paragraph 11(b)

Cases

R. v. Rahey (1984), 141 A.P.R. 275 (N.S.C.A.)

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Paragraph 11(c)

Cases

Tyler v. MNR, 89 DTC 5044 (FCTD), rev'd 91 DTC 5022 (FCA)

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Tax Topics - Income Tax Act - Section 241 - Subsection 241(3) 37

Paragraph 11(d)

Cases

James v. The Queen, 84 DTC 6570, [1984] CTC 672 (S.C.O.), rev'd by 86 DTC 6432, [1986] 2 CTC 288 (Ont CA), briefly aff'd by 88 DTC 6273, [1988] 2 CTC 1, [1988] 1 S.C.R. 669

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Tax Topics - Income Tax Act - Section 244 - Subsection 244(4) 90

Re Charron, 84 DTC 6241, [1984] CTC 237 (FCTD)

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See Also

Stanley J. Tessmer Law Corporation v. The Queen, 2013 TCC 27

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Paragraph 11(h)

Cases

The Queen v. Caseley, 90 DTC 6618 (P.E.I.S.C.)

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 63

Lavers v. Minister of Finance of B.C., 90 DTC 6017 (BCCA)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) 103

The Queen v. Sharma, 87 DTC 5424, [1987] 2 CTC 253 (S.C.O.)

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Section 12

Cases

Canada v. Guindon, 2013 DTC 5133 [at 6117], 2013 FCA 153, aff'd supra

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Subsection 15(1)

Cases

Almadhoun v. Canada, 2018 FCA 112

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Tax Topics - Income Tax Act - Section 122.6 - Eligible Individual - Paragraph (e) unsuccessful refugee claimant who was subsequently permitted to stay on compassionate grounds did not qualify 314
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) - Paragraph 171(1)(b) - Subparagraph 171(1)(b)(iii) TCC, after finding against the taxpayer, improperly directed CRA to “seriously” consider interest relief and tax remission 262
Tax Topics - Statutory Interpretation - Ordinary Meaning supposed purpose cannot supplant clear language 67

Deluca v Canada, 2016 ONSC 3865

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Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) no tort damages against CRA for tort damages based on its denial of deductions 261
Tax Topics - General Concepts - Negligence and Fiduciary Duty CRA has no duty to protect taxpayers from participating in tax shelters 344

Ali v. Canada, 2008 DTC 6446, 2008 FCA 190

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Fannon v. Canada Revenue Agency, 2012 DTC 5130 [at 7247], 2012 FC 876, aff'd 2013 DTC 5088 [at 5975], 2013 FCA 99

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Pilette v. Canada, 2010 DTC 5075 [at 6808], 2009 FCA 367

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Canada v. Wetzel, 2006 DTC 6189, 2006 FCA 103

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Canada (Attorney General) v. Campbell, 2006 DTC 6023, 2005 FCA 420

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Chua v. MNR, 2000 DTC 6527 (FCTD)

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Tax Topics - Treaties - Income Tax Conventions - Article 26A 28

Weeks v. Canada, 2001 DTC 5035 (FCA)

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The Queen v. Mercier, 97 DTC 5081 (FCTD)

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Vosicky v. The Queen, 96 DTC 6580 (FCA)

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Thibaudeau v. The Queen, 95 DTC 5273 (SCC)

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Lister v. The Queen, 94 DTC 6531 (FCA)

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Tax Topics - Income Tax Act - Section 122.5 65

Kasvand v. The Queen, 94 DTC 6271 (FCA)

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Schachtschneider v. The Queen, 93 DTC 5298 (FCA)

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OPSEU v. National Citizens' Coalition, 90 DTC 6326 (Ont CA)

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The Queen v. Kurisko, 88 DTC 6434, [1988] 2 CTC 254 (FCTD), aff'd 90 DTC 6376 (FCA)

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Wright v. Attorney-General of Canada, 88 DTC 6041, [1988] 1 CTC 107 (Ont. D. Ct.)

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R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) benefit based on actual rather than subjective value 91
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 95

Gerol v. A.G. Canada, 85 DTC 5561, [1986] 1 CTC 75 (S.C.O.)

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See Also

Leeper v. The Queen, 2015 DTC 1115 [at 733], 2015 TCC 82 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118 - 118(2) - 118(2)(n) supplements, vitamins and herbs not eligible 46
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 unavailability of tax credit for natural cancer remedies did not infringe the taxpayer's s. 7 rights 48

D'Ambrosio v. The Queen, 2014 DTC 1090 [at 3154], 2014 TCC 70 (Informal Procedure)

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Hall v. The Queen, 2013 DTC 1241 [at 1313], 2013 TCC 314 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts no charitable registration, no discrimination 44

Johnston v. The Queen, 2012 DTC 1175 [at 3437], 2012 TCC 177 (Informal Procedure)

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Astley v. The Queen, 2012 DTC 1162 [at 3394], 2012 TCC 155 (Informal Procedure)

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Stogrin v. The Queen, 2012 DTC 1021 [at 2599], 2011 TCC 532 (Informal Procedure)

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Fannon v. The Queen, 2012 DTC 1007 [at 2534], 2011 TCC 503 (Informal Procedure)

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Hotte v. The Queen, 2011 DTC 1011 [at 64], 2010 TCC 611 (Informal Procedure)

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Tall v. The Queen, 2009 DTC 187, 2008 TCC 677 (Informal Procedure)

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McKenna v. The Queen, 2005 DTC 1410, 2005 TCC 599 (Informal Procedure)

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Barrons v. The Queen, 95 DTC 483 (TCC)

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Weronski v. MNR, 91 DTC 1105 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(c.1) 44

Section 16

Cases

Yates v. The Queen, 2001 DTC 761 (TCC) (Informal Procedure)

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Subsection 20(1)

Cases

Kasvand v. The Queen, 94 DTC 6271 (FCA)

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Subsection 24(1)

Cases

Samaroo v. Canada Revenue Agency, 2018 BCSC 324

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Malicious Prosecution CRA dominated prosecution and knowingly misstated evidence 577
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 malicious prosecution breached a couple's s. 7 rights 210

R. v. Lagiorgia, 87 DTC 5245, [1987] 1 CTC 424 (FCA)

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Lagiorgia v. The Queen, 85 DTC 5554, [1985] 2 CTC 25 (FCTD), aff'd in part supra.

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Lewis v. M.N.R., 84 DTC 6550, [1984] CTC 642 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 return of seized items 20

Thyssen Canada Ltd. v. The Queen, 84 DTC 6049, [1984] CTC 64 (FCTD)

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Butler Manufacturing Co. (Canada) Ltd. v. MNR, 83 DTC 536 (S.C.O.)

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Subsection 24(2)

Cases

Donovan v. The Queen, 2000 DTC 6339 (FCA)

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R. v. Hazlewood, 93 DTC 5406 (BCSC)

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R. v. Agopsowicz, 93 DTC 5416 (Sask. P. Ct.)

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The Queen v. F.K. Clayton Group Ltd., 89 DTC 5417 (S.C.O.)

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R. v. James; Dzagic v. R., 86 DTC 6432, [1986] 2 CTC 288 (Ont.C.A.), briefly aff'd 88 DTC 6273, [1988] 1 S.C.R. 669

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 Charter effective date 22

Thyssen Canada Ltd. v. The Queen, 84 DTC 6049, [1984] CTC 64 (FCTD)

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Section 25

Cases

Rice v. ARQ, 2016 QCCA 666

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 35 - Subsection 35(1) s. 35 did not accord an unfettered right to trade 131
Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 status Indians were required to collect sales tax on sales to non-Indians 283
Tax Topics - Excise Tax Act - Section 221 - Subsection 221(1) status Indians were required to collect sales tax on sales to non-Indians 67
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 91 - Subsection 91(24) statutory verification obligations did not represent an ultra vires administrative burden 157

Section 35

Subsection 35(1)

Cases

Rice v. ARQ, 2016 QCCA 666

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 25 no unfettered right of Indians to trade 151
Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 status Indians were required to collect sales tax on sales to non-Indians 283
Tax Topics - Excise Tax Act - Section 221 - Subsection 221(1) status Indians were required to collect sales tax on sales to non-Indians 67
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 91 - Subsection 91(24) statutory verification obligations did not represent an ultra vires administrative burden 157