Ordinary Meaning

Table of Contents

Cases

Almadhoun v. Canada, 2018 FCA 112

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 122.6 - Eligible Individual - Paragraph (e) unsuccessful refugee claimant who was subsequently permitted to stay on compassionate grounds did not qualify 314
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) - Paragraph 171(1)(b) - Subparagraph 171(1)(b)(iii) TCC, after finding against the taxpayer, improperly directed CRA to “seriously” consider interest relief and tax remission 262
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Subsection 15(1) immigrant status not a protected s. 15 characteristic 255

Canada v. Cheema, 2018 FCA 45

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Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(b) third party who did not intend to occupy was liable at the purchase agreement time 335
Tax Topics - Excise Tax Act - Section 133 s. 133 effectively deemed an acquisition of a future new home at the time of signing the purchase agreement 255
Tax Topics - Statutory Interpretation - Ease of Administration interpretation that favours administrative efficiency is to be favoured 190
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations, No. 2 - Section 40 co-purchaser with no intended beneficial interest was required to satisfy ETA s. 254(2) rules 165
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) "legal acquirer" rather than intended beneficial owner was the purchaser 213

The Mark Anthony Group Inc. v. The Queen, 2017 TCC 141

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Tax Topics - Other Legislation/Constitution - Federal - Excise Act, 2001 - Section 135 - Subsection 135(2) - Paragraph 135(2)(a) exemption references wine “produced in Canada and, when produced, composed wholly of agricultural or plant product grown in Canada” 505

MacKay v. Canada, 2015 FCA 94, aff'g 2014 DTC 1059 [at 2959], 2014 TCC 33

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Tax Topics - Income Tax Act - Section 34.1 - Subsection 34.1(1) no relief for "harsh" (timing difference) consequences 137

Canada v. Quinco Financial Inc., 2014 FCA 108

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St. Arnaud v. Canada, 2013 DTC 5074 [at 5909], 2013 FCA 88

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Sheldon Inwentash and Lynn Factor Charitable Foundation v. Canada, 2012 FCA 136

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Toronto-Dominion Bank v. Canada, 2011 DTC 5125 [at 6061], 2011 FCA 221, [2011] 6 CTC 19

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Bastien Estate v. Canada, 2011 DTC 5118 [at 6014], 2011 SCC 38, [2011] 2 S.C.R. 710

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Exida.Com Limited Liability Company v. Canada, 2010 DTC 5101, 2010 FCA 159

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(2.1) no substantive tax liability 64
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) "penalty" does not include nil penalty 90
Tax Topics - Statutory Interpretation - Territorial Limits no filing requirement if no connection with Canada 77

Canada Trustco Mortgage Co., v. The Queen, 2005 DTC 5523, [2005] 2 S.C.R. 601, 2005 SCC 54

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit 126
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) policy of CCA provisions relied on cost irrespective of risk mitigation 207
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) "in contemplation" references "because of" or "in relation to" 115
Tax Topics - Statutory Interpretation - Certainty 127

Stewart v. Canada, 2002 DTC 6969, 2002 SCC 46, [2002] 2 S.C.R. 645

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Canada v. Citibank Canada, 2002 DTC 6876, 2002 FCA 128

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Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 supplied asphalt was merely an accession to customers' real property 146
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. 9

Maccabi Canada v. Canada (Minister of National Revenue), 98 DTC 6526 (FCA)

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Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103

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MCA Television Ltd. v. The Queen, 94 DTC 6375 (FCTD)

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Canada v. Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312

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R. v. Cappell, 92 DTC 6591 (Ont CA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 232 - Subsection 232(3.1) 68

British Columbia Telephone Co. Ltd. v. The Queen, 92 DTC 6129 (FCA)

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O'Sullivan v. The Queen, 90 DTC 6278 (FCTD)

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The Queen v. Morrissey, 89 DTC 5080 (FCA)

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C. & E. Cmners. v. West Yorkshire Hospital (Contract Services) Ltd., [1988] BTC 5095 (Q.B.D.)

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Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)

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The Queen v. Merali, 88 DTC 6173, [1988] 1 CTC 320 (FCA)

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Hodson v. The Queen, 88 DTC 6001, [1988] 1 CTC 2 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) 68

Canterra Energy Ltd. v. The Queen, 87 DTC 5019, [1987] 1 CTC 89 (FCA)

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D.MNR for Customs and Excise v. Amoco Canada Petroleum Co. Ltd., 86 DTC 6008, [1986] 1 CTC 124 (FCA)

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McBurney v. The Queen, 84 DTC 6494, [1984] CTC 466 (FCTD), rev'd 85 DTC 5433, [1985] 2CTC 214 (FCA)

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Pollon v. The Queen, 84 DTC 6139, [1984] CTC 131 (FCTD)

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Roome v. Edwards, [1982] A.C. 279 (HL)

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Tootal Broadhurst Lee Co. Ltd. v. I.R.C., [1949] 1 All E.R. 261 (HL)

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See Also

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

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Imperial Oil Ltd. v. The Queen, 2003 DTC 179, 2003 TCC 46

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MacNiven v. Westmoreland Investments Ltd., [2001] 1 All ER 865 (HL)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt interest paid with loan 124
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) capitalization of interest through payment and readvance respected 124
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Term Preferred Share 100

London Life Insurance Co. v. The Queen, 2000 DTC 1774 (TCC)

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McGorman v. The Queen, 99 DTC 699 (TCC)

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Wheeler v. The Queen, 97 DTC 1156 (TCC)

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