Words and Phrases - "contemplation"
Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, 2005 DTC 5523
"in contemplation" references "because of" or "in relation to"
In the course of a general discussion of the expression "series of transactions" apearing in ss. 245(2) and (3), the Court noted (at para. 26)...
Words and Phrases
contemplationLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit | tax benefit if taxable income reduction or on basis of comparison to alternative | 132 |
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | policy of CCA provisions relied on cost irrespective of risk mitigation | 211 |
Tax Topics - Statutory Interpretation - Certainty | interpretive approach should be consistent with tax law being certain, predictable and fair, | 131 |
Tax Topics - Statutory Interpretation - Ordinary Meaning | primacy to ordinary meaning if unequivocal | 96 |