Words and Phrases - "obiter dictum"

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

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