Oxford Properties Group Inc. v. The Queen, 2016 TCC 204
Jurisdiction | Federal Jurisdiction (Canada) |
Subject Matter | INCOME TAX,STATUTES |
Citation | 2016 TCC 204 |
Court | Tax Court (Canada) |
Date | 19 September 2016 |
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5 practice notes
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The Latest Word on Subsequent Legislative History and the GAAR
...Holdco Canada ULC v The Queen, 2016 TCC 159 [Univar] and Oxford Properties Group Inc v The Queen, 2016 TCC 204 [Oxford Properties], have added to the array of inconsistent and controversial case law on the role of subsequent legislative history in the GAAR When interpreting legislation, suc......
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Canada c. Oxford Properties Group Inc.,
...Vern. The Fundamentals of Canadian Income Tax , 9th ed. Toronto: Thomson/Carswell, 2006.APPEAL from a Tax Court of Canada decision (2016 TCC 204, [2017] 2 C.T.C. 2147 ) allowing the respondent’s appeal from a reassessment issued by the Minister of National Revenue pursuant to sectio......
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3295940 Canada Inc. v. The Queen, 2022 TCC 68
...in Triad Gestco Ltd. v. Canada, 2012 FCA 258 [Triad Gestco]. [57] Based on the holding of Oxford Properties Group Inc. v. The Queen, 2016 TCC 204, overturned on appeal, 2018 FCA 30, [Oxford], the appellant explained that the GAAR cannot apply to a purpose not specifically set out in a provi......
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Iberville Developments Limited v. The Queen, 2018 TCC 102
...the Honourable Marc Lalonde, Minister of Finance, December 1982, clause 58, page 98. [3] [1994] T.C.J. No. 585 (QL). [4] 2018 FCA 30. [5] 2016 TCC 204. The decision of the Federal Court of Appeal in Oxford Properties was released after the hearing and before additional written submissions w......
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3 cases
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Canada c. Oxford Properties Group Inc.,
...Vern. The Fundamentals of Canadian Income Tax , 9th ed. Toronto: Thomson/Carswell, 2006.APPEAL from a Tax Court of Canada decision (2016 TCC 204, [2017] 2 C.T.C. 2147 ) allowing the respondent’s appeal from a reassessment issued by the Minister of National Revenue pursuant to sectio......
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3295940 Canada Inc. v. The Queen, 2022 TCC 68
...in Triad Gestco Ltd. v. Canada, 2012 FCA 258 [Triad Gestco]. [57] Based on the holding of Oxford Properties Group Inc. v. The Queen, 2016 TCC 204, overturned on appeal, 2018 FCA 30, [Oxford], the appellant explained that the GAAR cannot apply to a purpose not specifically set out in a provi......
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Iberville Developments Limited v. The Queen, 2018 TCC 102
...the Honourable Marc Lalonde, Minister of Finance, December 1982, clause 58, page 98. [3] [1994] T.C.J. No. 585 (QL). [4] 2018 FCA 30. [5] 2016 TCC 204. The decision of the Federal Court of Appeal in Oxford Properties was released after the hearing and before additional written submissions w......
2 firm's commentaries
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The Latest Word on Subsequent Legislative History and the GAAR
...Holdco Canada ULC v The Queen, 2016 TCC 159 [Univar] and Oxford Properties Group Inc v The Queen, 2016 TCC 204 [Oxford Properties], have added to the array of inconsistent and controversial case law on the role of subsequent legislative history in the GAAR When interpreting legislation, suc......
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'Abuse' Under The GAAR Examined In Recent Federal Court Of Appeal Decision
...on subsequent amendments in the context of the GAAR, and the SCC may wish to clarify. Footnotes 1 2018 FCA 30 [Oxford Properties]. 2 2016 TCC 204. 3 2011 SCC 63 4 2017 FCA 207 [Univar]. About BLG The content of this article is intended to provide a general guide to the subject matter. Speci......