Interpretation/Definition Provisions

Cases

Canada (Attorney General) v. Igloo Vikski Inc., 2016 SCC 38

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Customs Tariff Act - Schedules - General Rules for the Interpretation of the Harmonized System - Rule 2 - Rule 2(b) good must be described in headings - even if not ultimately included therein because of their composite nature — before Rule 2 can apply 751
Tax Topics - Treaties narrower range of interpretations where implementing a Convention 69

Alexander College Corp. v. Canada, 2016 FCA 269

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - University private college providing "associate degrees" qualified as a “university” for GST purposes 178
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - 7 private college granting associate degrees qualified 134

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

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Survivance v. Canada, 2007 DTC 5096, 2006 FCA 129

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

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Placements Serco Lté v. The Queen, 88 DTC 6125 (FCA)

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Canada v. Schafer, 2000 DTC 6542 (FCA)

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Terrador Investments Ltd. v. Canada, 99 DTC 5358 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 93 - Subsection 93(1) 194

ITT Industries of Canada Ltd. v. The Queen, 99 DTC 5105 (FCTD), aff'd 2000 DTC 6445, Docket: A-99-99

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Liampat Holdings Ltd. v. The Queen, 96 DTC 6020 (FCTD)

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Qit-Fer et Titane Inc. v. The Queen, 92 DTC 6071 (FCTD), aff'd on different grounds 96 DTC 6213 (FCA)

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Derlago v. The Queen, 88 DTC 6290, [1988] 2 CTC 21 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) change of use on start of personal-use occupation 72

Dunstan v. Young, Austen & Young Ltd., [1987] BTC 530 (HCJ), rev'd [1989] BTC 77 (C.A.)

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Midyette v. The Queen, 85 DTC 5565, [1985] 2 CTC 362 (FCTD)

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Merchant v. The Queen, 84 DTC 6215, [1984] CTC 253 (FCTD)

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I.R.C. v. Metrolands (Property Finance) Ltd., [1981] 1 W.L.R. 637 (C.A.), aff'd 82 BTC 8032 (HL)

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The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205 (FCA)

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Words and Phrases
includes

The Queen v. Cie Imm. BCN Ltée, 79 DTC 5068, [1979] CTC 71, [1979] 1 S.C.R. 865

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R. v. Verrette, [1978] 2 S.C.R. 838

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Storrow v. The Queen, 78 DTC 6551, [1978] CTC 792 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 62 97

Toronto General Trusts Corporation v. The Minister of National Revenue, 58 DTC 1162, [1958] CTC 223, [1958] S.C.R. 499

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East End Dwellings Co. Ltd. v. Finsbury Borough Council, [1952] A.C. 109 at 132

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See Also

Barclays Wealth Trustees (Jersey) Limited v. Commissioners for Her Majesty's Revenue and Customs, [2017] EWCA Civ 1512

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) the determination of whether there is a single trust should accord with how a trust lawyer would view the matter 597

Cartier House Care Centre Ltd. v. The Queen, 2015 TCC 278

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - 1 - Home Care Service "personal care" included ADL assistance 383
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - 1 - Institutional Health Care Service accommodation an institutional health care service 200
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - 13 personal care services provided by independent contractors were exempted 459
Tax Topics - Excise Tax Act - Section 138 s. 138 did not apply where the allocation of consideration among the components was apparent 234
Tax Topics - Statutory Interpretation - Noscitur a Sociis noscitur a sociis did not apply to general phases preceding list 194

Presidential MSH Corporation v. The Queen, 2015 DTC 1101 [pp. 596-610], 2015 TCC 61

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 129 - Subsection 129(1) RDTOH not reduced by unclaimed dividend refunds 135

Vocalspruce Ltd. v. Revenue and Customs Commissioners, [2014] BTC 50, [2014] EWCA Civ 1302 (English CA)

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Words and Phrases
transaction

Roger Dubois Inc. v. The Queen, 2014 DTC 1094 [3167], 2013 TCC 409, briefly aff'd 2015 CAF 235

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(e) "antique" means "non-recent" 203
Tax Topics - Statutory Interpretation - Noscitur a Sociis no implied similarity requirement 140

Gill v. The Queen, 2012 DTC 1261 [at 3764], 2012 TCC 302

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Wunderlich v. The Queen, 2012 DTC 1040 [at 2676], 2011 TCC 539 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Eligible Relocation "new work location" does not require a change in work location 216

Klotz v. The Queen, 2004 DTC 2236, 2004 TCC 147, aff'd 2005 DTC 5279, 2005 FCA 158

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