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Federal Tax
COMMENT
This topic is mostly about income tax, though it includes the coordinated federal-provincial GST/HST systems and some other ancillary federal tax statutes and issues as well. I suspect income tax is the largest statutory regime in Canadian law (criminal and bank law are competitors) and I by no means attempt to give it adequate treatment here, so just think of this content as subject-organized Fed CA and SCC federal tax case extracts for roughly the last four years (updated near-daily). I hope to grow and enrich the topic but given other priority work that doesn't seem likely -- we could all use the public interest services of a retired tax lawyer (hint, hint).
INCOME TAX
General
Federal Tax - General
Federal Tax - Statutory Interpretation
Federal Tax - Procedural Fairness
Federal Tax - Constitutional
Basics
Taxation Concepts
Federal Tax - Income
Federal Tax - Residents
Federal Tax - Non-Residents
Federal Tax - Business Definition
Federal Tax - Taxable Benefit
Federal Tax - Capital Income/Loss
Federal Tax - "Spouse"
Federal Tax - Deductions
Federal Tax - Loss Carryback
Federal Tax - Value
Federal Tax - Depreciation
Federal Tax - 'Source of Income'
Taxation Entities
Federal Tax - Canada Revenue Agency (CRA)
Federal Tax - Minister of National Revenue
Procedures
Federal Tax - Assessments (+)
Federal Tax - Re-Assessments
Federal Tax - Settlements
Federal Tax - Interest
Federal Tax - Audits
Evidence
Federal Tax - Evidence
Tax Court of Canada
Federal Tax - Tax Court of Canada (+)
Appeals
Federal Tax - Appeals
Practice
Federal Tax - Practice
Types of Income
Corporations
Federal Tax - Corporations
Federal Tax - Liability of Corporate Directors
Federal Tax - Dividends
Federal Tax - Excess Elections
Federal Tax - Corporate Wind-Up
Farms
Federal Tax - Farming Loss Restriction Rule
Trusts
Federal Tax - Trusts
Investment
Federal Tax - Investment Income
Federal Tax - FAPI
Insurers
Federal Tax - Canadian Investment Fund
Federal Tax - Insurers
Resources
Federal Tax - Canadian Resource Properties
Exemptions and Special Treatment
Registered Plans and Similar
Federal Tax - RRSPs
Federal Tax - Retirement Compensation Arrangements (RCAs)
Federal Tax - TFSA
Tax Exemptions
Federal Tax - Charities
Federal Tax - Housing Rebate
Federal Tax - Fraternal Benefit Society
Specific Issues
Federal Tax - Sham
Federal Tax - Gambling
Federal Tax - Tax Shelter
Federal Tax - Tax versus Penalty
Federal Tax - Government Immunity
Federal Tax - Interaction with Provincial Tax Statutes
Enforcement
Much of income tax law is devoted to enforcement. Techniques like deemed trusts, witholding tax, non-arm's-length treatment -- and even statutory interpretive principles like the General Anti-avoidance Rule (GAAR) - which at first glance might seem to relate to substantive aspects of income tax law - are all essentially enforcement techniques. As well, the ITA has the typical full range of administrative and regulatory techniques at it's disposal to aid in enforcement.
Interpretation
Federal Tax - General Anti-avoidance Rule (+)
Enforcement Techniques
Federal Tax - Witholding Tax
Federal Tax - Deemed Trusts
Federal Tax - Investigations
Federal Tax - Penalties
Federal Tax - Voluntary Disclosure Program
Federal Tax - Information-Gathering
Federal Tax - Compliance Orders
Federal Tax - Criminal
Arm's Length Relationships
Federal Tax - Arm's Length (+)
Federal Tax - Transfer Pricing
Taxpayer Relief
Federal Tax - Taxpayer Relief
Related Statutes
Federal Tax - Excise Tax Act (ETA)
Federal Tax - Excise Act (EA)
Federal Tax - Payments in Lieu of Taxes Act
Treaties
Federal Tax - Tax Treaties
Federal Tax - Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital
GST/HST
Federal Tax - GST/HST
Federal Tax - Input Tax Credits
FEDERAL STATUTES
Canada and Taiwan Territories Tax Arrangement Act, 2016
Canada Disability Savings Act
Canada Education Savings Act
Canada Revenue Agency Act
Canada-Argentina Income Tax Convention Act, 1994
Canada–Armenia Tax Convention Act, 2004
Canada–Azerbaijan Tax Convention Act, 2004
Canada-Belgium Income Tax Convention Act, 1976
Canada-Brazil Income Tax Convention Act, 1984
Canada–Colombia Tax Convention Act, 2010
Canada–Finland Tax Convention Act, 2006
Canada–Gabon Tax Convention Act, 2004
Canada-Germany Tax Agreement Act, 1982
Canada–Greece Tax Convention Act, 2010
Canada–Hong Kong Tax Agreement Act, 2013
Canada–Ireland Tax Convention Act, 2004
Canada–Israel Tax Convention Act, 2016
Canada–Korea Income Tax Convention Act, 1980
Canada–Kuwait Tax Agreement Act, 2002
Canada–Madagascar Tax Convention Act, 2018
Canada–Mexico Tax Convention Act, 2006
Canada-Mexico Tax Information Exchange Convention Act, 1991
Canada–Moldova Tax Convention Act, 2002
Canada–Mongolia Tax Convention Act, 2002
Canada–Namibia Tax Convention Act, 2013
Canada–Norway Tax Convention Act, 2002
Canada–Oman Tax Agreement Act, 2004
Canada–Poland Tax Convention Act, 2013
Canada–Serbia Tax Convention Act, 2013
Canada–Turkey Tax Convention Act, 2010
Canada–United Arab Emirates Tax Convention Act, 2002
Canada–United States Enhanced Tax Information Exchange Agreement Implementation Act
Canada–United States Tax Convention Act, 1984
Charities Registration (Security Information) Act
Disability Tax Credit Promoters Restrictions Act [Not in force]
Dominion Succession Duty Act
Excise Act
Excise Act, 2001. Continuation of Amalgamated or Merged Corporations Regulations, SOR/2003-204
. Denatured and Specially Denatured Alcohol Regulations, SOR/2005-22
. Excise Duties on Cannabis Regulations, SOR/2019-78
. Excise Licences and Registrations, Regulations Respecting, SOR/2003-115
. Fees for the Examination of Instruments and the Provision of Tables, Regulations Respecting the, SOR/2003-207
. Information to be Displayed on Alcohol Containers and Their Packaging, Regulations Respecting the, SOR/2003-201
. Interest Rates (Excise Act, 2001) Regulations, SOR/2006-229
. Losses of Bulk Spirits and Packaged Alcohol Regulations, SOR/2003-206
. Possession of Non-duty-paid Packaged Alcohol, Regulations Respecting the, SOR/2003-205
. Possession of Tobacco Products or Cannabis Products That Are Not Stamped, Regulations Respecting the, SOR/2003-203
. Prescribed Brands of Manufactured Tobacco and Prescribed Cigarettes, Regulations Respecting, SOR/2011-7
. Relieving Special Duty on Certain Tobacco Products, Regulations, SOR/2003-202
. Return of Packaged Alcohol to an Excise Warehouse Regulations, SOR/2003-200
. Stamping and Marking of Tobacco Products Regulations, SOR/2003-288
. Excise Duties on Vaping Products Regulations, SOR/2024-70 Excise Tax Act Agriculture and Fishing Property (GST/HST) Regulations (SOR/91-39)
Air Transportation Tax Order, 1995 (SOR/95-206)
Air Transportation Tax Regulations, 1992 (SOR/93-294)
Amalgamations and Windings-Up Continuation (GST/HST) Regulations (SOR/91-33)
Artists’ Representatives (GST/HST) Regulations (SOR/91-25)
Automobile Operating Expense Benefit (GST/HST) Regulations (SOR/99-176)
British Columbia HST Regulations (SOR/2011-121)
Canadian Manufactured Goods Exported Drawback Regulations (SOR/78-373)
Closely Related Corporations (GST/HST) Regulations (SOR/91-21)
Credit for Provincial Relief (HST) Regulations (SOR/2011-57)
Credit Note and Debit Note Information (GST/HST) Regulations (SOR/91-44)
Deduction for Provincial Rebate (GST/HST) Regulations (SOR/2001-65)
Disclosure of Tax (GST/HST) Regulations (SOR/91-38)
Electronic Filing and Provision of Information (GST/HST) Regulations (SOR/2010-150)
Energy Conservation Equipment Exemption Regulations (C.R.C., c. 590)
Equivalent Courses (GST/HST) Regulations (SOR/91-27)
Excise Tax Indexing Ratio Regulations (SOR/83-681)
Federal Book Rebate (GST/HST) Regulations (SOR/98-351)
Federal Sales Tax Inventory Rebate Regulations (SOR/91-52)
Federal Sales Tax New Housing Rebate Regulations (SOR/91-53)
Financial Services and Financial Institutions (GST/HST) Regulations (SOR/91-26)
Formula Refunds Regulations (C.R.C., c. 591)
Games of Chance (GST/HST) Regulations (SOR/91-28)
Gasoline Excise Tax Regulations (SOR/2000-253)
General Excise and Sales Tax Regulations (C.R.C., c. 594)
Goods for Ships and Aircraft (Excise) Drawback Regulations (SOR/86-948)
Goods Imported and Exported Drawback Regulations (C.R.C., c. 489)
Health Care Services (GST/HST) Regulations (SOR/91-23)
Industrial Product Price Indices Adjustment Regulations (SOR/90-672)
Input Tax Credit Information (GST/HST) Regulations (SOR/91-45)
Interest Rates (Excise Tax Act) Regulations (SOR/2006-230)
Joint Venture (GST/HST) Regulations (SOR/91-36)
Mail and Courier Imports (GST/HST) Regulations (SOR/91-32)
Natural Gas and Gas Liquids Tax Regulations (SOR/82-359)
New Harmonized Value-added Tax System Regulations (SOR/2010-117)
New Harmonized Value-added Tax System Regulations, No. 2 (SOR/2010-151)
New Motor Vehicles Exported Drawback Regulations (SOR/82-710)
Non-Taxable Imported Goods (GST/HST) Regulations (SOR/91-31)
Nova Scotia HST Regulations, 2010 (SOR/2010-99)
Offset of Taxes (GST/HST) Regulations (SOR/91-49)
Property Supplied by Auction (GST/HST) Regulations (SOR/2001-66)
Public Service Body Rebate (GST/HST) Regulations (SOR/91-37)
Publications Supplied by a Registrant (GST/HST) Regulations (SOR/91-43)
Real Property (GST/HST) Regulations (SOR/2024-157)
Returnable Beverage Container (GST/HST) Regulations (SOR/2008-48)
School Cafeteria Food and Beverages (GST/HST) Regulations (SOR/91-29)
Security Interest (GST/HST) Regulations (SOR/2011-55)
Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations (SOR/2001-171)
Ships’ Stores Regulations (SOR/96-40)
Small Manufacturers or Producers Exemption Regulations (SOR/82-498)
Small Manufacturers Production Equipment Exemption Regulations (SOR/82-572)
Social Insurance Number Disclosure Regulations (SOR/91-41)
Specified Crown Agents (GST/HST) Regulations (SOR/99-175)
Specified Tangible Personal Property (GST/HST) Regulations (SOR/91-20)
Streamlined Accounting (GST/HST) Regulations (SOR/91-51)
Taxes, Duties and Fees (GST/HST) Regulations (SOR/91-34)
Telecommunication Programming Services Tax Regulations (SOR/86-895)
Value of Imported Goods (GST/HST) Regulations (SOR/91-30) Fruit and Vegetable Customs Orders Validation Act
Income Tax Act
Income Tax Application Rules
Income Tax Conventions Implementation Act, 1995
Income Tax Conventions Implementation Act, 1996
Income Tax Conventions Implementation Act, 1997
Income Tax Conventions Implementation Act, 1998
Income Tax Conventions Implementation Act, 1999
Income Tax Conventions Implementation Act, 2001
Income Tax Conventions Interpretation Act
Multilateral Instrument in Respect of Tax Conventions Act
Payments in Lieu of Taxes Act
Petroleum and Gas Revenue Tax Act
Tax Break for All Canadians Act
Tax Conventions Implementation Act, 2002
Tax Conventions Implementation Act, 2004
Tax Conventions Implementation Act, 2013
Tax Rebate Discounting Act
Tax-back Guarantee Act
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