Cases
Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67
The Crown submitted that the word “audit” in the power under in s. 231.1(1)(a) to “inspect, audit or examine” encompassed the authority to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) - Paragraph 231.1(1)(a) | Minister cannot under s. 231.1(1) compel oral answers to its questions other than for aid in auditing taxpayer books and records | 339 |
| Tax Topics - Statutory Interpretation - Redundancy/reading in words | CRA’s broad interpretation of s. 231.1(1)(a) would render s. 231.1(1)(d) redundant | 172 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | interpretation informed by legislative amendment narrowing the wording | 58 |
Immunovaccine Technologies Inc. v. Canada, 2014 DTC 5119 [at at 7309], 2014 FCA 196, aff'g 2013 DTC 1101 [at 531], 2013 TCC 103
The taxpayer unsuccessfully argued that the definition of "government assistance" in s. 127(9) did not cover amounts that the recipient was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | government loans made in a non-commercial capacity are "government assistance" | 100 |
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance | "government assistance" generally encompasses amounts advanced on non-commercial terms | 271 |
Walker v. Ritchie, 2006 SCC 45, [2006] 2 S.C.R. 428
The successful party, Mr. Ritchie, asked to have included, in his award of costs, a premium of $192,600 given that his counsel had carried the...
Words and Phrases
ejusdem generisHalpenny Estate v. Paddon, [1982] 1 S.C.R. 559
The words "accident", "inadvertence" and "impossibility" were found not to constitute a class for the purpose of applying the ejusdem generis rule...