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Cases

Contact Lens King Inc. v. Canada, 2022 CAF 154

The zero-rating for contact lenses in Sched. VI, Pt. II, s. 9 required that the contact lenses be supplied under the authority of a prescription...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part II - Section 9 a requirement to make supplies pursuant to a prescription did not require obtaining a copy of the prescription 462
Tax Topics - Excise Tax Act - Section 286 - Subsection 286(1) no particular form of documentary evidence required by s. 286(1) 228
Tax Topics - Income Tax Act - Section 230 - Subsection 230(1) taxpayer flexibility to determine corroborative documents 103

CIBC World Markets Inc. v. Canada, 2011 FCA 270

As ETA s. 141.01(5) did not stipulate that the choice of an ITC allocation method was irrevocable; irrevocability was not to be inferred.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(5) no implied irrevocability of choice of method 177
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) subsequent provision illustrates the missing words in current provision 112

Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103

After characterizing the Crown's proposed interpretation of the definition of "inventory" in s. 248(1) of the Act as a request to treat the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) loss recognized on decline in value of land held as an adventure 142
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory property held in an adventure was inventory 83
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate undeveloped land held in speculative venture 142
Tax Topics - Statutory Interpretation - Certainty 97
Tax Topics - Statutory Interpretation - Drafting Style 95
Tax Topics - Statutory Interpretation - Ordinary Meaning 80
Tax Topics - Statutory Interpretation - Resolving Ambiguity 97
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business s. 10(1) applied to an adventure in the nature of trade even if that deemed business was not “carried on” 75
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) property not generating income does not convert to capital property unless s. 13(7) or 45(1) applies 209

See Also

Veracity Capital Corp. v. The Queen, 2017 BCCA 3

In the course of her analysis of the B.C. GAAR (s. 68.1(1)), MacKenzie JA found it telling that s. 68.1(1)(d), unlike s. 68.1(1)(c), did not refer...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) avoidance of provincial capital gains tax was not GAARable in B.C. as there was no abuse of the B.C. Act itself 881

Canadian Occidental U.S. Petroleum Corp. v. The Queen, 2001 DTC 295 (TCC)

The taxpayer lent money on an interest-free basis to a non-resident wholly-owned subsidiary in 1988 and then, in November 1994, transferred the...

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