Words and Phrases - "obiter dictum"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

Canadian Imperial Bank of Commerce v. The Queen, 2021 TCC 71, aff'd 2023 FCA 91

Summary Under
Tax Topics - General Concepts - Stare Decisis
statement not obiter if it is an essential part of the Court’s reasoning

CIBC realized an FX loss of C$126.4 million in 2007 when shares of a US subsidiary for which it had subscribed US$1 billion were redeemed for US$1...

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Words and Phrases
obiter dictum
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.6) FX loss on share redemption arose under s. 40(1) and, therefore, was subject to s. 40(3.6) denial 344
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) s. 39(2) historically applied only to FX gains or losses on liabilities and foreign currency dispositions 275
Tax Topics - Statutory Interpretation - Prior Cases presumption that Parliament enacts with a knowledge of the jurisprudence 93