Comparison of Provisions

Cases

The Queen v. Gulf Canada Ltd., 92 DTC 6123, [1992] 1 CTC 183 (FCA)

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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Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175

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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AEL Microtel Ltd. v. The Queen, 84 DTC 6374, [1984] CTC 387 (FCTD), rev'd 86 DTC 6348, [1986] 2CTC 108 (FCA)

"[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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Bank of Nova Scotia v. The Queen, 80 DTC 6008, [1980] CTC 57, [1980] CTC 41, 80 DTC 6009 (FCTD), aff'd 81 DTC 5115, [1981] CTC 162 (FCA)

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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The Queen v. Guaranteed Homes Ltd., 78 DTC 6510, [1978] CTC 636 (FCTD)

"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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See Also

Prestcost (Central) Ltd. v. Minister of Labour, [1969] 1 W.L.R. 89 (C.A.)

(Referred to in Schwartz v. The Queen, 93 DTC 555 (TCC).)

At 97:

"... [T]he habit of a legal draftsman is to eschew synonyms. He uses the same...

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Administrative Policy

11 January 2005 Internal T.I. 2004-0104341I7 - Reclassify CDE of partnership to CEE

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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