Cases
R. v. Baudais, 2014 DTC 5071 [at 6973], 2014 BCSC 856
The accused argued that it was inappropriate for CRA to obtain a search warrant under s. 487 of the Criminal Code in respect of suspected offences...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(3) | CRA could obtain warrants under Criminal Code rather than tax statutes | 293 |
Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128
Before indicating that she chose not to rely on foreign cases cited to her, Sharlow J.A. stated:
"It is always interesting to learn how other...
| 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 - Legislative History | 57 |
Soper v. R., 97 DTC 5407, [1997] 3 C.T.C. 242 (FCA)
Robertson J.A. applied the "presumption of coherence between statutes" (at p. 5414) to find that s. 227.1(3) should be interpreted similarly to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) | 194 | |
| Tax Topics - Statutory Interpretation - Similar Statutes/ in pari materia | presumed coherence in federal statutes | 44 |
See Also
Black v. The Queen, 2014 DTC 1046 [at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275
Before finding that there was no inconsistency in the taxpayer being resident in Canada for purposes of the Act and a resident of the U.K. for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | amendments usually change the Act | 185 |
| Tax Topics - Treaties - Income Tax Conventions - Article 29 | Treaty residence not domestically applicable | 281 |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | Treaty residence not domestically applicable | 244 |