Certainty

Table of Contents

Certainty
Cases(7)
See Also(2)

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 396

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 142
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory property held in an adventure was inventory 83
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate undeveloped land held in speculative venture 142
Tax Topics - Statutory Interpretation - Drafting Style 95
Tax Topics - Statutory Interpretation - Inserting Words 104
Tax Topics - Statutory Interpretation - Ordinary Meaning 80
Tax Topics - Statutory Interpretation - Resolving Ambiguity 97
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business s. 10(1) applied to an adventure in the nature of trade even if that deemed business was not “carried on” 75
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) property not generating income does not convert to capital property unless s. 13(7) or 45(1) applies 209

The Queen v. Johnson & Johnson Inc., 94 DTC 6125 (FCA)

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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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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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