French and English Version

Table of Contents

Cases

Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) reasonable filing position position cannot be a “misrepresentation” 508
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege not necessary to provide legal opinion to rely on having consulted legal counsel 215
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) no fixed place of “business” if no source of business income 165
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business Marconi test of "business" applied outside source-of-income context 136

Conocophillips Canada Resources Corp. v. Canada (National Revenue), 2016 DTC 5016 [at 6588], 2016 FC 98, 2017 FCA 243 rev'd

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) discretion under s. 220(2.1) to waive filing a Notice of Objection 454
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Minister can consider reassessment without Notice of Objection 206

Brandon (City) v. Canada, 2010 FCA 244

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Words and Phrases
entretenir
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 21 s. 21 inapplicable because private company was not contractually obligated to provide its wastewater to the City plant 287
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 22 s. 22 extended to operation of a wastewater facility by City for private company 241

Medovarski v. Canada (Minister of Citizenship and Immigration); Esteban v. Canada (Minister of Citizenship and Immigration), 2005 SCC 51, [2005] 2 S.C.R. 539

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Canada v. Agazarian, 2004 DTC 6366, 2004 FCA 32

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Markevich v. Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 S.C.R. 94

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R. v. Jarvis, 2002 DTC 7547, 2002 SCC 73, [2002] 3 S.C.R. 757

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) cannot use audit powers if CRA predominant purpose is to establish criminal liability 100

S.T.B. Holdings Ltd. v. Canada, 2002 DTC 7450, 2002 FCA 386

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Hogg v. Canada, 2002 DTC 7037, 2002 FCA 177

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See Also

Hughes v. The Queen, 2017 TCC 95 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(2) no penalty if return filed within period demanded 261
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3) computation of penalty where extension 92

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 393
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) investment dealer fees re advisability of making hostile takeover were fully deductible 515
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales 170
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations 343
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) 228
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 131
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) expenses incurred in butterfly spin-off recognized as disposition expenses 61

Gill v. The Queen, 2016 TCC 13 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(b) primary-residence intention determined at signing of purchase contract 224
Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(g) post-acquisition occupation was "temporary and sporadic" 65

Bolduc v. The Queen, [2013] GSTC 38, 2013 TCC 77

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 304 - Subsection 304(5) narrower English version prevailed 94

Genex Communications inc. v. The Queen, 2010 DTC 1064 [at 2840], 2009 TCC 583, rev'd 2011 DTC 5061 [at 5707], 2010 FCA 353)

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943372 Ontario Inc. v. The Queen, 2007 DTC 1051, 2007 TCC 294

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Cleveland v. The Queen, 2003 DTC 2199, 2004 TCC 34 (Informal Procedure)

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