Words and Phrases - "consequence of"
Bank of Nova Scotia v. Canada, 2024 FCA 192
“as a consequence of” interpreted in light of the shared meaning of the French and English versions
In finding that the phrase “as a consequence of” in s. 161(7)(b)(iv) required a causal connection, Woods JA stated (at paras. 32-34):
[B]oth...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 161 - Subsection 161(7) - Paragraph 161(7)(b) - Subparagraph 161(7)(b)(iv) | interest on an audit adjustment accrued up to the time that the taxpayer, learning of the adjustment, requested a loss carryback to offset it | 408 |
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | Minister has the discretion to reject a loss carryback request | 137 |
Tax Topics - Statutory Interpretation - Certainty | Parliament seeks certainty, predictability and fairness | 112 |