Scheme

Table of Contents

Cases

Excelsior Life Insurance Co. v. The Queen, 85 DTC 5164, [1985] 1CTC 213 (FCTD)

"An interpretation which is on key with the statute as a whole is to be preferred. I agree with counsel in respect of this principle but I do not...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) segregated and non-segregated funds were same source of income 44

The Queen v. Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)

Since s. 20(1)(c) was thought to be almost a mirror image of s. 12(1)(e), case law as to the meaning of the latter was found to be relevant to the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Dominion of Canada General Insurance Co. v. The Queen, 84 DTC 6197, [1984] CTC 190 (FCTD), aff'd 86 DTC 6154, [1986] 1CTC (FCA)

"If the [statutory] words are imprecise so as to give rise to the possibility of two constructions then they should be interpreted in the manner...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122, 84 DTC 6126 (FCA)

"While it may not always be easy to find harmony and consistency in the provisions of the Income Tax Act the Court must, as it seems to me,...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Highway Sawmills Limited v. Minister of National Revenue, 66 DTC 5116, [1966] CTC 150, [1966] S.C.R. 384

In connection with finding that land upon which the timber had been removed should be regarded as part of a timber limit, in order to avoid the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

See Also

Erb v. The Queen, 00 DTC 1401 (TCC)

Bowman TCJ. applied the dictum in Shannon Realties, Ltd. v. Ville de St. Michel, [1924] A.C. 185 (PC) that "where alternative constructions are...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.