Redundancy/reading in words

Table of Contents

Cases

Canada (National Revenue) v. Cameco Corporation, 2017 FC 763

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) - Paragraph 231.1(1)(d) s. 231.1(1)(d) does not accord CRA an unfettered right to interview taxpayer personnel 417
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 95 - Subsection 95(1) unfettered CRA interview right would undercut Rules and proportionality principle 250

Canada (National Revenue) v. Thompson, 2016 SCC 21, [2016] 1 S.C.R. 381

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege exclusion for accounting records was invalid even where CRA demands related to enforcement action against the lawyer 509
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. Hansard indicated an intent for an amendment to trench on privilege 103

Caithkin, Inc. v. Canada, 2015 FCA 118

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John Doe v. Ontario (Finance), 2014 SCC 36, [2014] 2 S.C.R. 3

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 21 exclusion for "advice or recommendations" applied to draft policy papers 192

Envision Credit Union v. The Queen, 2010 DTC 1399 [at 4585], 2010 TCC 576, aff'd 2012 DTC 5055 [at 6842], 2011 FCA 321, aff'd 2013 DTC 5144 [at 6275], 2013 SCC 48

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Canada v. Remai, 2009 DTC 5188 [at 6257], 2009 FCA 340

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) no abuse in controlling funds established 155
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) providing a favour is consistent with arm's length dealing 218

A.Y.S.A. Amateur Youth Soccer Association v. Canada (Revenue Agency), 2007 DTC 5527, 2007 SCC 42, [2007] 3 S.C.R. 217

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Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. shifting CRA position could not be relied upon except to evidence ambiguity 73
Tax Topics - Statutory Interpretation - Resolving Ambiguity residual presumption in favour of the taxpayer 125
Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) cash-settled derivatives had the effect of fixing mine production] 399
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges “hedging “ includes cash settled derivatives including options 415
Tax Topics - Statutory Interpretation - Regulations addition of regulation did not significantly expand scope of tax 223

Ray v. Canada, 2004 DTC 6028, 2004 FCA 1

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Canada (National Revenue) v. Kitsch, 2003 DTC 5540, 2003 FCA 307

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Markevich v. Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 S.C.R. 94

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Montgomery v. Canada, 99 DTC 5186 (FCA)

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GSW Appliances Ltd. v. The Queen, 98 DTC 6010 (FCA)

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Bolton v. The Queen, 96 DTC 6413 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) Minister's failure to act with all due dispatch is not a basis for vacating an assessment 87

Extendicare Health Services Inc. v. MNR, 87 DTC 5404, [1987] 2CTC 179 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 246 - Subsection 246(2) 21

Shell Canada Resources Ltd. v. MNR, 84 DTC 6129, [1984] CTC 169 (FCA)

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The Queen v. Savage, 83 DTC 5409, [1983] CTC 393, [1983] 2 S.C.R. 428

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Goyer Estate v. The Queen, 78 DTC 6159, [1978] CTC 205 (FCTD)

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See Also

Cascades Inc. v. The Queen, 2008 DTC 2387, 2007 TCC 730

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