Territorial Limits

Table of Contents

Cases

1068754 Alberta Ltd., trustee of DGGMC Bitton Trust v. ARQ, 2018 QCCA 8 (Quebec Court of Appeal)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) the ARQ did not exceed its Quebec-based audit authority when it issued a s. 231.2 demand to a Calgary bank branch 450

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 - Ordinary Meaning purposive interpretation must be consistent with words 87

Society of Composers, Authors and Music Publishers of Canada v. Canadian Assn. of Internet Providers, [2004] 2 S.C.R. 427, 2004 SCC 45

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Oceanspan Carriers Ltd. v. The Queen, 85 DTC 5621, [1986] 1 CTC 114 (FCTD), aff'd in part 87 DTC 5102, [1987] 1 CTC 210 (FCA)

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Clark v. Oceanic Contractors Inc., [1982] BTC 417, [1983] 1 All E.R. 133 (HL)

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Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) carrying on trade was sufficient connection to jurisdiction 113

United States of America v. Harden, 63 DTC 1276, [1963] CTC 450, [1963] S.C.R. 366

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Tax Topics - Statutory Interpretation - Revenue Rule U.S. tax judgment not enforceable in Canada 120

See Also

Jimenez, R. (On the Application of) v The First Tier Tribunal (Tax Chamber), [2019] EWCA Civ 51

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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) sending a demand for information to a former UK resident did not entail an exercise of extraterritorial enforcement jurisdiction but merely entailed the potential imposition of UK penalties against any UK assets 622

Oroville Reman & Reload Inc. v. Canada, 2016 TCC 75

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Articles

Baker, "The Trans-National Enforcement of Tax Liabilities", 1993 British Tax Review, No. 5, p. 313.