Cases
McGillivray Restaurant Ltd. v. Canada, 2016 FCA 99
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) | de facto control includes only significant influence over the board of directors | 370 |
Canada Trustco Mortgage Co., v. The Queen, 2005 DTC 5523, [2005] 2 S.C.R. 601, 2005 SCC 54
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit | tax benefit if taxable income reduction or on basis of comparison to alternative | 126 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | policy of CCA provisions relied on cost irrespective of risk mitigation | 207 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | "in contemplation" references "because of" or "in relation to" | 115 |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | primacy to ordinary meaning if unequivocal | 90 |
Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Purpose/Intention | objective and subjective manifestations of purpose | 98 |
| Tax Topics - General Concepts - Tax Avoidance | right to structure for tax avoidance | 121 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | ancillary purpose of earning (1%-yield) dividend income/allocation of reinvested proceeds 100% to income-producing source | 362 |
Brill v. The Queen, 96 DTC 6572 (FCA)
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Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | loss recognized on decline in value of land held as an adventure | 140 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | property held in an adventure was inventory | 81 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | undeveloped land held in speculative venture | 136 |
| Tax Topics - Statutory Interpretation - Drafting Style | 87 | |
| Tax Topics - Statutory Interpretation - Inserting Words | 98 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | 74 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 87 |
The Queen v. Johnson & Johnson Inc., 94 DTC 6125 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 52 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | 147 |
J.L. Guay Ltée v. MNR, 71 DTC 5423, [1971] CTC 686 (FCTD), aff'd 73 DTC 5374, [1973] CTC 506 (FCA), aff'd 75 DTC 5094, [1975] CTC 97 (SCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 89 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 75 |
See Also
High-Crest Enterprises Limited v. The Queen, 2015 TCC 230, nullified on procedural grounds 2017 FCA 88
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 191.1 - Subsection 191.1(1) - Government Funding | government funding only of operating costs did not detract from its objective of increasing beds | 245 |
| Tax Topics - General Concepts - Purpose/Intention | government funding only of operating costs did not detract from its purpose of increasing beds | 211 |
Daishowa-Marubeni International Ltd. v. The Queen, 2010 DTC 1216 [at 3582], 2010 TCC 317, rev'd in part 2013 DTC 5085 [at 5959], 2013 SCC 29
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Realization Principle | 80 |