Words and Phrases - "business conducted"
Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51
“business conducted,” as contrasted to “business,” did not include the raising of capital
In finding that the business of a Barbados subsidiary of the taxpayer was not a “business conducted principally with persons with whom [it did]...
Words and Phrases
business conductedLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - General Concepts - Foreign Law | meaning of banking business under Barbados law was not persuasive | 234 |
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (a) | bank business was conducted with arm's length persons notwithstanding that capital raised from shareholder | 581 |
Tax Topics - Statutory Interpretation - Certainty | full effect should be given to Parliament’s precise and unequivocal words to produce certainty | 88 |
Tax Topics - Statutory Interpretation - Speaking in vain | Parliament does not speak in vain | 72 |
Tax Topics - Income Tax Act - Section 91 - Subsection 91(1) | two policies balanced in FAPI regime | 79 |
Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius | specific addition of a competition requirement in another provision implied that there was no such requirement here | 152 |