Noscitur a Sociis

Table of Contents

Cases

The Queen v. Vancouver Art Metal Works Ltd., 93 DTC 5116, [1993] 1 CTC 346 (FCA)

Létourneau J.A. noted (at p. 5118) that an order for the noscitur a sociis rule to apply "there must be a distinct genus or category from which...

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British Columbia Telephone Co. Ltd. v. The Queen, 92 DTC 6129, [1992] 1 CTC 26 (FCA)

After noting that the noscitur a sociis doctrine should only be applied with great caution, MacGuigan J.A. found that there is no warrant to...

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

With respect to a submission that the more general word "management" in the phrase "management or administration fee" in s. 212(1)(a) should be...

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Customs and Excise Commissioners v. Viva Gas Appliances Ltd., [1983] BTC 5064, [1983] 1 WLR 1445, [1984] 1 All E.R. 112 (HL)

"In the case of a word which is capable of bearing various shades of meaning, the fact that it is included in a list of words of greater...

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Howden Brothers Construction Ltd. v. The Queen, 80 DTC 6393, [1980] CTC 529 (FCTD)

It was held with respect to the meaning of the word "mould" in the phrase "a die, jig, pattern, mould or last", that all the other descriptive...

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Tory Estate v. M.N.R., 73 DTC 5354, [1973] CTC 434 (FCA), briefly aff'd 76 DTC 6312, [1976] CTC 415 (SCC)

The meaning of the word "transferred" in the phrase "transferred or distributed to beneficiaries" was held to be coloured by the meaning of the...

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See Also

Lichtman v. The Queen, 2017 TCC 252 (Informal Procedure)

In the course of discussing the meaning of “congregation” in the phrase “ministering to a diocese, parish or congregation” in s. 8(1)(c),...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(c) religious instructors at a Hebrew academy did not qualify for the clergy residence deduction 284

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

Paris J rejected CRA arguments that independent contractors who provided personal care services to a B.C. for-profit residential care home,...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Home Care Service "personal care" included ADL assistance 409
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service accommodation an institutional health care service 232
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 13 personal care services provided by independent contractors were exempted 483
Tax Topics - Excise Tax Act - Section 138 s. 138 did not apply where the allocation of consideration among the components was apparent 254
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions general phases in definition not limited by following specific enumeration 185
Tax Topics - Excise Tax Act - Regulations - Public Service Body Rebate (GST/HST) Regulations - Section 2 - Government Funding funding for personal care services provided by independent contractors would be included 265

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

The taxpayer unsuccessfully argued that Reg. 1102(1)(e)(iv) referred "to decorative objects and not objects that are used, as is the case with the...

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Besner v. The Queen, 2008 DTC 4299, 2008 TCC 404

V.A. Miller J was assisted in her conclusion that "complaint" in s. 239(3) of the Act meant the initiating of a judicial proceeding by its...

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