Cases
Burchill v. Canada, 2010 DTC 5096 [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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | 75 |
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...
| 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...
| 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....
| 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.,...