Consistency

Table of Contents

Cases

Lawyers’ Professional Indemnity Company v. Canada, 2020 FCA 90

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(d.5) LPIC was not exempt under s. 149(1)(d.5) because its owner, the Law Society, did not provide municipal-type services 452
Tax Topics - Statutory Interpretation - Interpretation Act - Section 14 marginal notes may be considered as part of the interpretive process 96
Tax Topics - Statutory Interpretation - Redundancy/reading in words narrower construction avoided rendering language redundant 81

Barejo Holdings ULC v. Canada, 2020 FCA 47

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) - Paragraph 94.1(1)(a) the amount payable under a “debt” for s. 94.1(1)(a) purposes need not be crystallized until maturity 650
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract 3 tests for what constituted debt under s. 94.1(1)(a) 290

Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65

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Words and Phrases
appeal
Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.1 - Subsection 18.1(2) correctness appellate standard for questions of law not generally applicable to s. 18.1 reviews 941
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) correctness standard applied to questions of law of central importance, reasonableness standard applicable to most reviews 515
Tax Topics - General Concepts - Stare Decisis prior decisions can be departed from where this will reduce uncertainty 176
Tax Topics - Statutory Interpretation - Ordinary Meaning administrative decisions must have regard to the provision’s text, context and purpose 214

Canada v. Tallon, 2015 DTC 5082 [at 6023], 2015 FCA 156

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(g) warm climate not a "medical service" 176
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. Hansard referred to in purposive interpretation 51

Confessions Productions Inc. v. The Queen (BC), 2014 DTC 5069 [at 6961], 2014 BCSC 813

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Canada v. Lehigh Cement Limited, 2014 DTC 5058 [at 6849], 2014 FCA 103, aff'g 2013 DTC 1139 [at 740], 2013 TCC 176

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(6) - Paragraph 95(6)(b) restricted to status-manipulating acquisitions or dispositions 335
Tax Topics - Statutory Interpretation - Headings provision not in Tax Avoidance Part of Act 137

See Also

4145356 Canada Limited v. The Queen, 2011 DTC 1171 [at 937], 2011 TCC 220

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Bozzer v. Canada, 2010 DTC 5025 [at 6612], 2010 FC 139, rev'd 2011 DTC 5106 [at 5922], 2011 FCA 186

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