Rule 3(1)
Cases
Linett v. The Queen, 79 DTC 5471, [1980] CTC 36 (FCA)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 167 - Subsection 167(4) | 51 |
Rule 26
Subsection 26(1)
Cases
Rémillard v. Canada (Revenu national), 2020 CF 1061
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 318 - Subsection 318(1) | the certified Federal Court record is open to the public absent a specific confidentiality order | 583 |
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | public access to the certified court record in a judicial review application did not entail an unreasonable search or seizure | 434 |
Rule 65
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
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Rule 71
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
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Rule 75
Cases
McKesson Canada Corporation v. Canada, 2014 FCA 290
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|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 346 | long factums are bad advocacy | 143 |
Rule 114
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
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Rule 302(b)
Rule 303
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
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Rule 306
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
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Rule 313(2)
Rule 317
Cases
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
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Rule 318
Rule 318(4)
Cases
Athletes 4 Athletes Foundation v. Canada (National Revenue), 2020 FCA 41
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Words and Phrases
with such modifications as are necessary| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 172 - Subsection 172(3) - Paragraph 172(3)(a) | Minister required to produce any irrelevant material (e.g., on other Foundations) before her in her decision | 197 |
Subsection 318(1)
Cases
Rémillard v. Canada (Revenu national), 2020 CF 1061
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|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 26 - Subsection 26(1) | open court principle applied in finding that the certified Federal Court record is open to the public absent a specific confidentiality order | 369 |
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | public access to the certified court record in a judicial review application did not entail an unreasonable search or seizure | 434 |
Rule 319(1)
Cases
Stephens v. The Queen, 84 DTC 6169 (FCTD)
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| Tax Topics - General Concepts - Evidence | 15 |
Rule 324
Cases
The Queen v. Muir, 85 DTC 5038, [1985] 1 CTC 26 (FCTD)
In re Athenian Construction Ltd., 81 DTC 5352 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 223 - Subsection 223(1) | 41 |
Rule 332(1)
Cases
Can-Am Industrial Auctioneers Inc. v. Rompkey, 84 DTC 6151, 82 DTC 6255 (FCTD)
In re Romeo's Place Victoria Ltd., 81 DTC 5295, [1981] CTC 380 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 35 | |
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(5) | 73 |
Rule 332(5) [Affidavits]
Rule 334.16(1)
Rule 337(2)(b)
Cases
Dym v. The Queen, 79 DTC 5362, [1979] CTC 442 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 177 - Paragraph 177(b) | 43 |
Rule 337(6)
Rule 341 [Judgment on Admissions]
Cases
The Queen v. Gary Bowl Ltd., 74 DTC 6401, [1974] C.T.C 457 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 | 7 | |
| Tax Topics - Income Tax Act - Section 172 - Subsection 172(1) | 83 |
Rule 344(1) [Costs]
Cases
The Queen v. Lagiorgia, 87 DTC 5378 (FCA)
Farmer Construction Ltd. v. The Queen, 84 DTC 6331, [1984] CTC 370 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 87 |
Smith v. The Queen, 84 DTC 6164, [1984] CTC 105 (FCTD)
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|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 344(7) | 34 |
The Queen v. Pongratz, 82 DTC 6200, [1982] CTC 259 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(1) | 73 |
Rule 344(7)
Cases
Salt v. The Queen, 85 DTC 5055, [1985] 1 CTC 57 (FCTD)
Smith v. The Queen, 84 DTC 6164, [1984] CTC 105 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 344(1) [Costs] | 65 |
Rule 346
Cases
McKesson Canada Corporation v. Canada, 2014 FCA 290
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|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 75 | amendment allowed to address allegation that trial judge's commenting on appeal memorandum was improper | 207 |
Rule 351
Rule 355(4)
Cases
Lipsey v. MNR, 85 DTC 5080, [1984] CTC 675 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 1211(1) | 19 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 101 |
Rule 401(c)
Cases
Usarco Ltd. v. A.G. Canada, 80 DTC 6308, [1980] CTC 484 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Paragraph 50(1)(b) | 51 | |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(4) | 17 |
Rule 408(1)
Cases
The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 39 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | s. 12(1)(a)(i) inapplicable to deposits | 47 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | balance of purchase price did not become receivable until condition precedent satisfied | 92 |
| Tax Topics - Income Tax Act - Section 9 - Timing | 42 |
Woodbine Developments Ltd. v. The Queen, 84 DTC 6556, [1984] CTC 616 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 179 |
The Queen v. Consumers' Gas Co. Ltd., 84 DTC 6058, [1984] CTC 83 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 1104(1) | 104 | |
| Tax Topics - Income Tax Act - Section 180 - Subsection 180(3) | 49 |
The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 24 | |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | 99 |
Rule 413(1)(a)
Rule 419(1)(a) [Striking out Pleadings]
Rule 420 [Amendment of Pleadings]
Cases
The Queen v. Mohawk Oil Co. Ltd., 92 DTC 6135 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 68 | |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | damages received both for breach re depreciable property and lost profits | 68 |
The Queen v. McLeod, 90 DTC 6281 (FCTD)
DeConinck v. The Queen, [1985] 1 CTC 36 (FCTD)
The Queen v. Chrapko, 84 DTC 6544, [1984] CTC 594 (FCTD), rev'd 88 DTC 6487, [1988] 2 CTC 342 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 85 | |
| Tax Topics - Income Tax Act - Section 67 | 69 |
Rule 433
Rule 440 [Want of Prosecution]
Rule 448(1)
Cases
The Queen v. Special Risks Holdings Inc., 83 DTC 5046, [1983] CTC 36 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Tax Avoidance | 89 |
Rule 455 [Discovery]
Cases
Roseland Farms Ltd. v. The Queen, 90 DTC 6512 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 67 |
Rule 465(1)(b)
Cases
Indalex Ltd. v. The Queen, 84 DTC 6018, [1984] CTC 51 (FCTD), aff'd on other grouns 84 DTC 6492, [1984] CTC 373 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(15) | 42 | |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(19) | 27 |
Rule 465(1)(c)
Rule 465(15)
Cases
Indalex Ltd. v. The Queen, 84 DTC 6018, [1984] CTC 51 (FCTD), aff'd on other grouns 84 DTC 6492, [1984] CTC 373 (FCA)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(1)(b) | 27 | |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(19) | 27 |
Carruthers v. The Queen, 82 DTC 6009, [1982] CTC 5 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 88 | |
| Tax Topics - General Concepts - Fair Market Value - Shares | 244 |
Rule 465(19)
Cases
The Queen v. Indalex, 84 DTC 6492, [1984] CTC 373 (FCA)
Indalex Ltd. v. The Queen, 84 DTC 6018, [1984] CTC 51 (FCTD), aff'd on other grouns 84 DTC 6492, [1984] CTC 373 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(1)(b) | 27 | |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(15) | 42 |
Rule 469
Rule 474
Rule 482
Cases
Yager v. The Queen, 85 DTC 5494, [1985] 1 CTC 89 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Shares | 62 |
Rule 483(4)
Cases
Special Risks Holdings Inc. v. The Queen, 84 DTC 6054, [1984] CTC 71 (FCTD), aff'd 84 DTC 6215, [1984] CTC 563 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Abuse of Process | extremely late motion for further discovery | 81 |
| Tax Topics - Income Tax Act - Section 231.2 | 40 |
Rule 1102(1)
Rule 1104(1)
Cases
The Queen v. Consumers' Gas Co. Ltd., 84 DTC 6058, [1984] CTC 83 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 408(1) | 53 | |
| Tax Topics - Income Tax Act - Section 180 - Subsection 180(3) | 49 |
Rule 1211(1)
Cases
Lipsey v. MNR, 85 DTC 5080, [1984] CTC 675 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 355(4) | 30 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 101 |