Interpretation Bulletins, etc.

Cases

Canada v. Marchessault, 2008 DTC 6496, 2007 FCA 345

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 128 - Subsection 128(2) 106
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions related interpretation provision not referenced 106

Imperial Oil Ltd. v. Canada, 2004 DTC 6702, 2004 FCA 361, rev'd 2006 SCC 46

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Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 114
Tax Topics - Statutory Interpretation - Resolving Ambiguity residual presumption in favour of the taxpayer 125
Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) cash-settled derivatives had the effect of fixing mine production] 399
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges “hedging “ includes cash settled derivatives including options 415
Tax Topics - Statutory Interpretation - Regulations addition of regulation did not significantly expand scope of tax 223

Canada v. Whitney, 2002 DTC 7145, 2002 FCA 266

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Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260

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OSFC Holdings Ltd. v. Canada, 2001 DTC 5471, 2001 FCA 260

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London Life Insurance Co. v. Canada, [2000] GSTC 111 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Improvement 100
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) leasehold construction services were acquired for supply of leasehold improvements to landlord 167
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) leasehold construction services were acquired for supply of leasehold improvements to landlord 206

Owen Holdings Ltd. v. The Queen, 97 DTC 5401 (FCA)

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Riddell v. The Queen, 95 DTC 5526 (FCTD)

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Ludmer v. The Queen, 95 DTC 5311 (FCA)

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The Queen v. Fibreco Export Inc., 95 DTC 5412 (FCA)

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Ludmer v. The Queen, 95 DTC 5311 (FCA)

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Harvey C. Smith Drugs Ltd. v. The Queen, [1995] 1 C.T.C. 143 (FCA)

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Connaught Laboratories Limited v. The Queen, 94 DTC 6697 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 161 - Subsection 161(7) 141

The Queen v. Silden, 93 DTC 5362 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) loan to 1/3 shareholder made in ordinary course but without specific repayment arrangement 211

The Queen v. Kieboom, 92 DTC 6382 (FCA)

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First Fund Genesis Corp. v. The Queen, 91 DTC 5361 (FCTD)

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Vaillancourt v. The Queen, 91 DTC 5408 (FCA)

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Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085 (FCTD), aff'd 91 DTC 5543 (FCA)

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Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175

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Johnson & Johnson Inc. v. D.MNR, 88 DTC 6235, [1988] 2CTC 1 (FCTD)

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Smith, Kline & French Laboratories Ltd. v. A.G. Can. (1987), 12 F.T.R. 81

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West Hill Redevelopment Co. Ltd. v. The Queen, 87 DTC 5210, [1987] 1CTC 310 (FCTD)

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The Queen v. Hoffman, 85 DTC 5508, [1985] 2 CTC 347 (FCTD)

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Mother's Pizza Parlour Ltd. v. The Queen, 85 DTC 5271, [1985] 1 CTC 361 (FCTD), aff'd supra.

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O'Brien v. The Queen, 85 DTC 5202, [1985] 1 CTC 285 (FCTD)

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Reilly Estate v. The Queen, 84 DTC 6001, [1984] CTC 21 (FCTD)

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The Queen v. Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)

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Nowegijick v. The Queen, 83 DTC 5041, [1983] CTC 20, [1983] 1 S.C.R. 29

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Wicks v. Firth, [1982] BTC 402 (HL)

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Brown v. The Queen, 79 DTC 5421, [1979] CTC 476 (FCTD)

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Harel v. Deputy Minister of Revenue (Quebec), 77 DTC 5438, [1977] CTC 441, [1978] 1 S.C.R. 851

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See Also

Alta Energy Luxembourg S.A.R.L. v The Queen, 2018 TCC 152

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 13 a large exploration property in which only six wells had been drilled qualified as immovable property used in the business 390
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) no abuse in non-resident investors using a s.à r.l. to avoid capital gains tax on a new Canadian exploration company 368

Pêcheries Yvon Savage Inc. v. The Queen, 2012 DTC 1059 [at 2781], 2011 TCC 477

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FLSmidth Ltd. v. The Queen, 2012 DTC 1052 [at 2745], 2012 TCC 3, aff'd 2013 DTC 5118 [at 6147], 2013 FCA 160

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Fleet v. Canada (Attorney General), 2010 DTC 5094 [at 6912], 2010 FC 609

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Parker Brothers Textile Mills Limited v. The Queen, 2007 DTC 610, 2007 TCC 74

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Karia v. Canada (Minister of National Revenue), 2005 DTC 5282, 2005 FC 639

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Kruco Inc. v. The Queen, 2001 DTC 668 (TCC), aff'd 2003 FCA 284

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Safety Boss Ltd. v. The Queen, 2000 DTC 1767 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) conferral on corp increasing its value is benefit conferred on shareholder 143
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) 289

CSI Development Corp. v. The Queen, 99 DTC 1139 (TCC)

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Northwest Hydraulic Consultants Ltd. v. The Queen, 98 DTC 1839 (TCC)

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Ainsley Financial Corp. v. Ontario Securities Commission, 21 O.R. (3d) 104, 121 D.L.R. (4th) 79 (C.A.)

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Kaplan Estate v. The Queen, 94 DTC 1816 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 13 period starts running no earlier than 1972 157

R. v. Inland Revenue Commissioners, Ex Parte Matrix Securities Ltd., [1994] BTC 85 (HL)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 325

Ouellet v. The Queen, 94 DTC 1315 (TCC)

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Stevens v. MNR, 93 DTC 291 (TCC)

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Texasgulf, Inc. v. U.S., 89-1 U.S.TC 88079 (US Cl. Ct.)

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International Brotherhood of Teamsters v. Daniel, 439 U.S. 551 (1979)

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Administrative Policy

21 November 2017 CTF Roundtable Q. 7, 2017-0724261C6 - CRA Update

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85 C.T. - Q.4

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85 C.R. - Q27

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85 C.R. - Q.43

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80 C.R. - Q.1

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79 C.R. - Q.8

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