Words and Phrases - "following"
S.T.B. Holdings Ltd. v. Canada, 2002 DTC 7450, 2002 FCA 386
The Court rejected a submission that s. 245(7) required that, in order for GAAR to be applied, the reassessment notice must state on its face that...
Words and Phrases
followingLocations of other summaries | Wordcount | |
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Tax Topics - Statutory Interpretation - French and English Version | 21 |
J.K. Read Engineering Ltd. v. The Queen, 2014 DTC 1216 [at at 3872], 2014 TCC 309
GAAR applies to impose liability for abusive transactions from inception
The taxpayers acknowledged that capital losses (purportedly generated under schemes similar to Global Equity, 1207192 and Triad Gestco) should be...
Words and Phrases
followingLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - General Concepts - Stare Decisis | weight of obiter depends on fulness of argument | 93 |
Tax Topics - General Concepts - Stare Decisis | weight of obiter depends on fullness of argument | 93 |
Tax Topics - Income Tax Act - Section 161 - Subsection 161(1) | interest under GAAR assessments accrued from balance due dates | 54 |