Legislative History

Sharlow, J.A. found that a statement in the Budget papers respecting the introduction of the withholding tax exemption in s. 212(1)(b)(viii), that...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4)	withholding exemption where no money raised not abusive	270

The Court inferred (para. 45) from the repeal of ss.231.2(3)(c) and (d) that in the provision as amended "Parliament permitted a type of fishing...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3)		134
Tax Topics - Statutory Interpretation - Headings		51

The legislative history of the rules applicable to registered Canadian amateur athletic associations showed that Parliament intended them to be a...

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Pelletier J.A. applied the principle (at p. 6376) that "in order to ascertain Parliament's intent in enacting the provision, one may look to the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b)	s. 152(4)(b)(i) permits more than one reassessment within the extended period	165
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01)		58
Tax Topics - Statutory Interpretation - French and English Version		115

Comments made at the time of the enactment of the 1948 Act indicated that it was not intended to effect substantive tax reform. This, in turn,...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property	"property" entails an exclusive right	147
Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business	non-taxable non-compete	35
Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement		35
Tax Topics - Statutory Interpretation - Other/Conflicting Statutes	foreign statutory context different	78

Létourneau J.A. indicated that his view, that the phrase "trader or dealer in securities" in s. 39(5) was not restricted to dealers who are...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(5) - Paragraph 39(5)(a)	"trader or dealer" need not be licensed	67
Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius	restriction applied to only one case implies not applicable elsewhere	106
Tax Topics - Statutory Interpretation - Noscitur a Sociis		66

Any doubt as to the meaning of s. 6(1)(o) was "entirely removed by a consideration as to how the law stood and the state of things existing at the...

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"[H]ow can you understand the true meaning and effect of an amendment unless you bear in mind the state of the law which it is proposed to amend?"

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax		268

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