Cases
Canada (Attorney General) v. Emamifar, 2026 FCA 141
After finding that a failure of the applicant to fulfil her commitment (made at the time of applying for mat leave EI benefits) to report a return...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | a failure to fulfil a commitment to report a return to work while collecting mat leave EI benefits was not a “misrepresentation” | 399 |
| Tax Topics - Other Legislation/Constitution - Federal - Employment Insurance Act - Section 52 - Subsection 52(5) | failure to fulfil an undertaking to report an early return to work was not a "misrepresentation" | 310 |
Onex Corporation v. Canada (Attorney General), 2024 FC 1247
Regarding the CRA position that the implied exclusion rule of statutory interpretation indicated that Parliament did not intend ss. 220(2.1) and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3) | CRA failed to consider, in light of the remedial nature of s. 220(3), that it could be used to permit an amended return that accomplished a late election not listed in Reg. 600 | 641 |
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) | CRA should consider, in light of the remedial nature of ss. 20(2.1) and (3), that they could be used to accommodate a late election not listed in Reg. 600 | 615 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 42 - Subsection 42(3) | s. 220(2.1) permitted the waiver of an election under an amending Bill itself | 138 |