Rule 3(1)
Cases
Linett v. The Queen, 79 DTC 5471, [1980] CTC 36 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries | Wordcount | |
---|---|---|
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Rule 71
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Rule 75
Cases
McKesson Canada Corporation v. Canada, 2014 FCA 290
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries | Wordcount | |
---|---|---|
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Rule 306
Articles
Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Rule 318
Rule 318(4)
Cases
Athletes 4 Athletes Foundation v. Canada (National Revenue), 2020 FCA 41
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
with such modifications as are necessaryLocations 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries | Wordcount | |
---|---|---|
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries | Wordcount | |
---|---|---|
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 344(7) | 34 |
The Queen v. Pongratz, 82 DTC 6200, [1982] CTC 259 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries | Wordcount | |
---|---|---|
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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(19) | 27 |
Carruthers v. The Queen, 82 DTC 6009, [1982] CTC 5 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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 |