Words and Phrases - "includes"
The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205 (FCA)
"including" enlarges
After being referred to the statement in Verrette [1978] 2 S.C.R. 838 at 844 that "in definition provisions, the word 'includes' is generally used extensively in contradistinction to the restrictive word 'means'," Heald J.A. accepted (at p. 6160) a submission of the Crown that the word "including" in s. 212(1)(d) was used in its extensory sense for the purpose of enlarging the meaning of the preceding words, so that payments described after the word "including" were subject to the charge of the section whether or not they could be said to be ejusdem generis with "rent, royalty or a similar payment".
Words and Phrases
includes| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | failure of Minister to allocate | 57 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | right to buy and resell product not a right to use | 204 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | lump sum paid irrespective of user not "royalty" | 143 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 13 |