Cases
Lehigh Cement Limited v. Canada, 2010 DTC 5081 [at at 6844], 2010 FCA 124
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...
Canada (National Revenue) v. Greater Montréal Real Estate Board, 2008 DTC 6420, 2007 FCA 346
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...
A.Y.S.A. Amateur Youth Soccer Association v. Canada (Canada Revenue Agency), 2006 DTC 6314, 2006 FCA 136
The legislative history of the rules applicable to registered Canadian amateur athletic associations showed that Parliament intended them to be a...
Canada v. Agazarian, 2004 DTC 6366, 2004 FCA 32
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...
Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128
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,...
The Queen v. Vancouver Art Metal Works Ltd., 93 DTC 5116, [1993] 1 CTC 346 (FCA)
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...
MNR v. Shawinigan Water and Power Co., 53 DTC 1036, [1953] CTC 37 (Ex Ct)
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...
London County Council v. A.G., [1901] A.C. 26, 4 TC 265 (HL)
"[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?"
See Also
Entertainment Software Association v. Society of Composers, Authors and Music Publishers of Canada, 2012 SCC 34, [2012] 2 S.C.R. 231
The Society of Composers, Authors and Music Publishers of Canada ("SOCAN") would negotiate with individual game publishers (collectively...
Weyerhaeuser Company Limited v. The Queen, 2012 DTC 1132 [at at 3166], 2012 TCC 106
Paris J. found that "logging operations" refers to "ongoing activities that are carried on by a taxpayer" (para. 50), and therefore the taxpayer...