Words and Phrases - "misrepresentation"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
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88
t
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Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i)
reasonable filing position cannot be a “misrepresentation”

In order to avoid B.C. provincial income tax on a capital gain of $336.2 million which was realized on a sale in 2002 of a control block of a...

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Words and Phrases
misrepresentation
Locations of other summaries Wordcount
Tax Topics - General Concepts - Solicitor-Client Privilege not necessary to provide legal opinion to rely on having consulted legal counsel 225
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) no fixed place of “business” if no source of business income 183
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business Marconi test of "business" applied outside source-of-income context 154
Tax Topics - Statutory Interpretation - French and English Version "misrepresentation" informed by narrower French version 109

9 November 2012 CTF Atlantic Roundtable, 2012-0465921C6 - CTF Atlantic - Statute Barred Years

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i)
"misrepresentation"
1. What is "misrepresentation"?

There is no requirement that the person providing the information intended to deceive the CRA ... . ... [T]he...

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Words and Phrases
misrepresentation

Ver v. Canada, [1995] TCJ No. 593

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i)
failure to plead the precise misrepresentation (which means misrepresentation of fact)

The Minister's reassessment of the taxpayers' 1988 taxation year beyond the normal reassessment period, on the basis that various claimed expenses...

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Words and Phrases
misrepresentation

MNR v. Foot, 64 DTC 5196, [1964] CTC 317 (Ex Ct), briefly aff'd 66 DTC 5072 (SCC)

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i)
reticence or incorrectness as misrepresentation

The taxpayer, who underreported his income in his returns but pleaded (p. 5197) that "he honestly believed in the truth of the information...

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Words and Phrases
misrepresentation

Nesbitt v. The Queen, 96 DTC 6045, [1996] 1 CTC 282 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i)
typo was a misrepresentation

In preparing the taxpayer's return, the taxpayer's accountant erroneously reported the taxpayer's share of a capital gain as $71,139.42 rather...

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Words and Phrases
misrepresentation