Words and Phrases - "ascertainable"

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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...

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Words and Phrases
ascertainable merchant
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...

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Words and Phrases
ascertainable

Merchant 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]...

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Words and Phrases
office ascertainable