Words and Phrases - "as a 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 | |
---|---|---|
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 |
Attorney General of Canada v. Hoefele, 95 DTC 5602, [1996] 1 CTC 131 (FCA)
new mortgage debt of relocated employees
Employees of Petro-Canada who were required to relocate from Calgary to Toronto had a declining percentage of their increased interest costs...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - General Concepts - Tax Avoidance | form matters | 82 |
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | interest rate subsidy did not increase net worth | 102 |