Expressio Unius est Exclusio Alterius

Cases

Copthorne Holdings Ltd. v. Canada, 2012 DTC 5006 [at 6536], 2011 SCC 63, [2011] 3 S.C.R. 721

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis high threshold for reversing not met 193
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit tax benefit illuminated by comparison to reasoanble alternative 315
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) policy of s. 87(3) is to avoid preservation of PUC on parent and sub amalgamation 372
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) "in contemplation" could be retrospective 342

A.Y.S.A. Amateur Youth Soccer Association v. Canada (Revenue Agency), 2007 DTC 5527, 2007 SCC 42, [2007] 3 S.C.R. 217

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R. v. Dimsey, [2001] BTC 408 (HL)

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Allcolour Paint Ltd. v. The Queen, 97 DTC 5266 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(8) 48

Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence failure to report revenue did not evidence its non-receipt 42
Tax Topics - General Concepts - Onus taxpayer demolished Minister's assumptions with uncontradicted testimony 41
Tax Topics - General Concepts - Payment & Receipt unrecorded revenues 148
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit 85
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) brief earning of rental income 130
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit reasonable expectation of profit test directed only at existence of business source 85
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) integrated farming equipment and auto leasing 95
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) generation of revenue for a short time was sufficient 352
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) deemed property to be acquired for an income-producing purpose 37
Tax Topics - Statutory Interpretation - Drafting Style absence of specific-hold period was telling 85
Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 26

Royal Bank of Canada v. Sparrow Electric Corp., 97 DTC 5089, [1997] 1 S.C.R. 411

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The Queen v. Nassau Walnut Investments Inc., 97 DTC 5051 (FCA)

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) late s. 55(5)(f) designation available 194
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(f) late s. 55(5)(f) designation available 162

The Queen v. Vancouver Art Metal Works Ltd., 93 DTC 5116 (FCA)

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The Queen v. Taylor, 84 DTC 6234, [1984] CTC 244 (FCTD)

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Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) 58

Ketz v. The Queen, 79 DTC 5142, [1979] CTC 186 (FCTD)

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Associated Investors of Canada Ltd. v. MNR, 67 DTC 5096 (Ex. Ct.)

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Minister of National Revenue v. Trans-Canada Investment Corporation Ltd., 55 DTC 1191, [1955] CTC 275, [1956] S.C.R. 49

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 112 - Subsection 112(1) dividend-received deduction flowed through an investment trust 115
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 83

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496

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See Also

Richard Lewin Re: The J.J. Herbert Family Trust #1 v. The Queen, 2011 DTC 1354 [at 1979], 2011 TCC 476, aff'd 2013 DTC 5006 [at 5525], 2012 FCA 279 [but overridden by s. 214(3)(f)(i)(C)]

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Honeywell Limited v. The Queen, 2006 DTC 3124, 2006 TCC 325

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Landry v. The Queen, 98 DTC 1416 (TCC) (Informal Procedure)

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