Context

Table of Contents

Cases

Burchill v. Canada, 2010 DTC 5096 [at at 6922], 2010 FCA 145

The Court rejected the taxpayer's argument that the reference in s. 56(1)(a)(i) to pension benefits "received" referred to benefits...

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Giannakopoulos v. The Queen, 95 DTC 5477, [1995] 2 CTC 316 (FCA)

After finding that the 40 kilometer distance referred to in s. 62(1) of the Act should be measured on the basis of the shortest normal route to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 62 72

The Queen v. Old HW-GW Ltd., 93 DTC 5199, [1993] 1 CTC 363 (FCA)

MacGuigan J.A. applied the "words-in-total-context approach" in finding that because Puerto Rico was a country for purposes of Regulations...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 80

The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209

It was found that in s. 68, a "potential ambiguity is resolved with reference to the other words of the section, which must be given meaning".

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property "property" includes a contract right, or potentially covenant to deliver knowhow 78
Tax Topics - Income Tax Act - Section 68 100

The Queen v. British Columbia Forest Products Ltd., 85 DTC 5577, [1986] 1CTC 1 (FCA)

In finding that the taxpayer had "received" investment tax credits for purposes of the pre-1978 version of s. 13(7.1), Mahoney J.A....

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) 42

Bourne (H.M.I.T.) v. Norwich Crematorium Ltd. (1967), 44 TC 164 (Ch.D.)

An unsuccessful argument was made that a crematorium qualified as a building in use for the subjection of goods or materials to any process (i.e.,...

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Articles

Joel A. Nitikman, "Some Plain Talk About Statutory Interpretation", Canadian Current Tax, June 1992, p. C101.