Comparison of Provisions

In finding that the reference to employment in the definition of retiring allowance referred only to the loss of current employment rather than...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 180 - Subsection 180(3)	no deference to FCA factual findings	95
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Employment		46
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance	pre-employment termination damages were not a retiring allowance	62
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit		53
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a)	quaere whether income can be from a non-enumerated source	39
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1)		83
Tax Topics - Income Tax Act - Section 68		95
Tax Topics - Statutory Interpretation - Specific v. General Provisions	specific statutory rule should not be undercut by a more general rule	76

In interpreting the word "production" the Court noted (p. 6126):

"There is a strong, indeed overwhelming, presumption that Parliament, having used...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 124.1 - Subsection 124.1(1)		56
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (a)	no connection betweeen lease payments and exploration	131

In response to a submission of the Minister that in the absence of a separate definition for the section, "income" had a different meaning in s....

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose	direct causal connection to income need not be demonstrated	155
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(a) - Revising Claims		77
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc.		34
Tax Topics - Statutory Interpretation - Resolving Ambiguity		56

"[W]here in the same Act, and in relation to the same subject matter, different words are used such choice of different words must be considered...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(5)		65
Tax Topics - Statutory Interpretation - Title		61

The Court was affected by the consideration that "it is more consistent that the same measure be applicable to subparagraphs (a) and (b) of...

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"Words used more than once in a statute may not always have the same meaning, but they are normally considered to have the same meaning unless the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(ee)		127

The word "taxpayer" in subsection 66.1(9) of the Act and in paragraph (e) of the definition of CEE should be interpreted as referring only to a...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (e)		86
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(9)		277

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