Canada v. Loblaw Financial Holdings Inc.,
| Jurisdiction | Federal Jurisdiction (Canada) |
| Judge | Wagner, Richard; Moldaver, Michael J.; Karakatsanis, Andromache; Côté, Suzanne; Brown, Russell; Martin, Sheilah; Kasirer, Nicholas |
| Neutral Citation | 2021 SCC 51 |
| Citation | 2021 SCC 51 |
| Date | 03 December 2021 |
| Court | Supreme Court (Canada) |
| Docket Number | 39220 |
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12 practice notes
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Csak v. The King, 2024 TCC 9
...26; see also R. v. J.D., 2022 SCC 15 , at para. 21). [144] In paragraphs 41 and 61 of Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51, the Supreme Court of Canada elaborates on this approach in the income tax This narrow question of statutory interpretation requires us to d......
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Independent Order of Foresters v. The King, 2023 TCC 123
...liabilities. [35] ITA subsection 248(1). [36] ITR subsection 2400(1) definition of “Canadian reserve liabilities”. [37] 2021 SCC 51. [38] Ruth Sullivan, The Construction of Statutes, 7th ed. (Toronto: LexisNexis, 2022) at pages 345-346; Ruth Sullivan, Statutory Interpretation,......
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Stackhouse v. The King, 2023 TCC 156
...[the Court] to focus carefully on the text and context in assessing the broader purpose” (R. v. Loblaw Financial Holdings Inc., 2021 SCC 51 at paragraph [91] The text of subsection 31(1) is deceptively straightforward. The restriction on the deductibility of farm losses in subsection......
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Google LLC v. Canada (Privacy Commissioner), 2023 FCA 200
...in vain, and that it would not have legislated an exemption whose terms could never be met: Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51 at para. 64. I note again in this regard that the focus of paragraph 4(2)(c) is different from that of paragraph 4(1)(a): the inclusionary provis......
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11 cases
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Csak v. The King, 2024 TCC 9
...26; see also R. v. J.D., 2022 SCC 15 , at para. 21). [144] In paragraphs 41 and 61 of Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51, the Supreme Court of Canada elaborates on this approach in the income tax This narrow question of statutory interpretation requires us to d......
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Independent Order of Foresters v. The King, 2023 TCC 123
...liabilities. [35] ITA subsection 248(1). [36] ITR subsection 2400(1) definition of “Canadian reserve liabilities”. [37] 2021 SCC 51. [38] Ruth Sullivan, The Construction of Statutes, 7th ed. (Toronto: LexisNexis, 2022) at pages 345-346; Ruth Sullivan, Statutory Interpretation,......
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Google LLC v. Canada (Privacy Commissioner), 2023 FCA 200
...in vain, and that it would not have legislated an exemption whose terms could never be met: Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51 at para. 64. I note again in this regard that the focus of paragraph 4(2)(c) is different from that of paragraph 4(1)(a): the inclusionary provis......
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Stackhouse v. The King, 2023 TCC 156
...[the Court] to focus carefully on the text and context in assessing the broader purpose” (R. v. Loblaw Financial Holdings Inc., 2021 SCC 51 at paragraph [91] The text of subsection 31(1) is deceptively straightforward. The restriction on the deductibility of farm losses in subsection......
Request a trial to view additional results
1 firm's commentaries
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Considering A Move To Canada? Income Tax For Permanent Residence For Wealthy Immigrants
...the cash generated by those passive investment activities. The Supreme Court of Canada in Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51, recognized that the FAPI regime is one of the most complicate statutory regimes in Canadian law. It is extraordinarily important when immigrating ......