Words and Phrases - "ascertainable"
Canada (National Revenue) v. Shopify Inc., 2025 FC 968
s. 231.2(3)(b) currently did not authorize unnamed person requirements pursuant to treaty information-exchange Articles
The respondent (Shopify), was a Canadian corporation providing a software platform for online e-commerce transactions. After receiving a request...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Consistency | presumption of consistent expression | 214 |
| Tax Topics - Treaties - Income Tax Conventions - Article 27 | Art. 21 of Canada-Australia Treaty did not expand the scope of s . 231.2(3) unnamed person requirement to include Treaty-requested information | 163 |
Rockport Developments Inc. v. The Queen, 2009 TCC 180
consideration was not ascertained until contractual dispute resolved
The appellants were subcontractors of an affiliated company (“Exelon”) which, in turn, had a contract for the performance of construction work...
Words and Phrases
ascertainableMerchant v. The Queen, 84 DTC 6215, [1984] CTC 253 (FCTD)
specified amount per sitting may be sufficient
After stating (at p. 6217) tht "I am not convinced that at the time of taking office the taxpayer must know how much he will receive.... [A]...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 118 | |
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "means" is exhaustive | 55 |