Regulations/Statutory Delegation

Cases

Canada v. The Mark Anthony Group Inc., 2019 FCA 183

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Excise Act, 2001 - Section 135 - Subsection 135(2) - Paragraph 135(2)(a) all-ingredients test applied to each alcoholic component – not to all components 320

Canada v. Société des alcools du Québec, 2002 FCA 69

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 120 - Subsection 120(5) liquor board was entitled to a full rebate of the FST included in its liquor inventory as the Reg. did not give effect to the legislative intent to avoid double taxation 323

British Columbia Ferry Corp. v. Canada, 2001 FCA 146

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Alaska Trainship Corporation et al. v. Pacific Pilotage Authority, [1981] 1 S.C.R. 261

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Irving Oil Ltd. et al. v. Provincial Secretary of New Brunswick, [1980] 1 S.C.R. 787

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Carling Export Brew & Malt Co. v. The King, [1931] A.C. 435 (P.C.)

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See Also

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 79
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 120
Tax Topics - Statutory Interpretation - Resolving Ambiguity residual presumption in favour of the taxpayer 133
Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) cash-settled derivatives had the effect of fixing mine production] 453
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges “hedging “ includes cash settled derivatives including options 461

Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) no withholding on reimbursements for disbursements/no requirement for documentary support for allocations in NRs' invoices/travel time to Canada not re Cdn services 499
Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 "in respect of" in Regulation read narrowly to conform with "for" in statute 169