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 AGREEMENTS............15
 agreements . 1478
The clause in the conditional sales  agreements  obliging the buyer to insure the tractors against 1544
legal title reserved in the seller by the conditional sales  agreements , such as possession, risk and 1548
 agreements  and legal relations arising from the actions of the parties to those agreements must 1620
agreements and legal relations arising from the actions of the parties to those  agreements  must 1620
contracts for the lease of trucks. The lease  agreements  contained an option to purchase the 1674
govern their relationship by retroactive  agreements : Trollope Colls et al. v. Atomic Power 2272
 agreements , where the seller reserves the title to secure payment of the sale price. This concept 2374
. Many  agreements  contemplate the reacquisition by the vendor of property that has been 2672
. Formal  agreements  of purchase and sale are frequently explicit as to the date of exchange 2984
financial leasing  agreements . However, the problem would still exist where the parties failed 3490
KROFT, E. G., Tax Clauses in Acquisition  Agreements  in Corporate Management Tax 3850
Acquisition  Agreements  in Corporate Management Tax Conference, (Toronto: 4250
REVENUE CANADA, Interpretation Bulletin IT-R, Lease Option  Agreements  4346
and Sale Leaseback  Agreements , February , . 4346
 
 AGREES................5
a buyer who  agrees  to pay the price if the seller agrees to deliver the item is contracting a pure 170
a buyer who agrees to pay the price if the seller  agrees  to deliver the item is contracting a pure 170
commitments. One party  agrees  to pay the price, and the other agrees to transfer ownership of 794
commitments. One party agrees to pay the price, and the other  agrees  to transfer ownership of 794
The Department of Finance  agrees  that the tax legislation must take the relevant provinciallaw 2948
 
 AGRICOLE..............2
(Commission de la protection du territoire  agricole ) where the Court addressed the 772
Venne v. Québec (Commission de la protection du territoire  agricole ), S.C.R. 3742
 
 AIMED.................1
examination of the current situation,  aimed  at predicting likely developments in the law and 158
 
 AL....................3
govern their relationship by retroactive agreements: Trollope Colls et  al . v. Atomic Power 2272
GUEST, A. G. et  al ., Chitty on Contracts, thed., vol. (London: Sweet Maxwell, 3764
Art. ,  al . C.C.Q. See V. KARIM, supra note at . 4076
 
 ALBEIT................2
this is unsatisfactory, it is sufficient,  albeit  necessary, that the federal statute supply its own 1338
retroactivity provided for in the provincial act did not apply to the I.T.A.,  albeit  for very different 2502
 
 ALBERT................3
 Albert  MAYRAND, Le droit comparé et la pensée juridique canadienne, () R. 3984
occurrence of the condition.  Albert  MAYRAND, Dictionnaire de maximes et locutions 4062
Ibid., para. . From  Albert  MOREL, Harmonizing Federal Legislation with the Civil 4306
 
 ALBERTA...............6
After establishing this test, the Court went on to examine the private law in  Alberta , in order to 1482
determine the moment when ownership is transferred. Under the  Alberta  Sale of Goods Act 1484
to  Alberta  law, which provided that ownership was transferred when the property was finished 1490
stated by Cattanach J. derives from the Supreme Court of  Alberta  judgment in Hendrickson v. 1512
gave rise to a sale under Rule I of s. of the  Alberta  Sale of Goods Act, despite the fact that 1514
The Supreme Court of  Alberta  came to this conclusion in accordance with the intent of the 1522
 
 ALBRECHT..............2
 ALBRECHT , D. J., Sale of Land Subject to Conditions Meaning of Receivable () 3786
D. J.  ALBRECHT , Sale of Land Subject to Conditions Meaning of Receivable, 4460
 
 ALEPIN................13
The Federal Courts decision in  Alepin  v. The Queenhas been cited in support of the 1958
(now the CCRA). In  Alepin , three brothers had sold their land to Jar Investments Ltd. The 1960
A dispute arose between the  Alepin  brothers and Revenue Canada regarding the nature of a 1964
In , the  Alepin  brothers exercised their rights under the resolutory clause and took back 1970
Superior Court subsequently annulled the sale at the taxpayers request. The taxpayer in  Alepin  2008
The judge rejected this argument based mainly on the decision of Marceau J. in  Alepin : 2010
(para. .()),  Alepin  (para. .()) and Adam (para. .()). In these cases, the courts 2016
despite the orders retroactive effect. The judgments in  Alepin , Larose and Riverin 2560
Moreover, in Clément  Alepin  ( DTC ) and Michel Larose ( DTC ), the courts 2942
We have already expressed our doubts regarding the general application of  Alepin  and 2962
 Alepin  v. The Queen, C.T.C. (F.C.T.D.); 3660
C.T.C. (F.C.T.D.) hereinafter  Alepin . 4374
 Alepin , supra note at para. . 4378
 
 ALIA..................6
of property is pivotal in determining, inter  alia , the moment at which a capital gain is taxed, 140
December , is contained in subsection () which provides inter  alia  as follows: 1180
See Blacks Law Dictionary, which defines a beneficial owner as being inter  alia : One who 1508
law. In addition, it is significant that Parliament, which annually amends the Act inter  alia  to 1784
definition of the term transfer found at section of that Act refers, inter  alia , to the transfer of 3182
within the concept of disposition, i.e. there is a disposition, inter  alia , when the seller is entitled to 3298
 
 ALIENATE..............4
to use it, to destroy it, and lastly, to  alienate  it, that is, to transmit it to another.1582
. The prerogatives of jus abutendi. The right to  alienate  includes, aside from the 1592
right to abandon the thing and to destroy it, two significant prerogatives: the right to  alienate  the 1592
than to  alienate  (though the appellant would have wanted it to limit it that way) but certainly 1596
 
 ALIENATED.............2
conditione from a thing  alienated  subject to a condition ...: retroactivity attached to a fulfilled 552
conditione from a thing  alienated  subject to a condition ...: retroactivity attached to a fulfilled 652
 
 ALIENATES.............2
The person who  alienates  property does not have to restore the fruits collected pendente 550
The person who  alienates  property is not required to restore the fruits collected pendente 652
 
 ALIENATION............6
. Acts of  alienation  by onerous title performed by a person who is bound to make 282
whom restitution is owed. Acts of  alienation  by gratuitous title may not be set up, subject to the 284
One should begin by noting that the acts of  alienation  contemplated in the first paragraph of 290
. In the case of total loss or  alienation  of property subject of restitution, the person liable to 444
received, or at the time of its loss or  alienation , whichever value is the lowest, or, if the person is 446
enjoyment, of destruction, alteration and  alienation , and of maintaining and recovering 980
 
 ALIENATIONS...........3
otherwise be subject to any  alienations , servitudes or hypothecs granted by the alienator 554
otherwise be subject to any  alienations , servitudes or hypothecs granted by the seller pendente 654
benefit the buyer, who would otherwise be subject to any  alienations , servitudes or hypothecs 2084
 
 ALIENATOR.............1
otherwise be subject to any alienations, servitudes or hypothecs granted by the  alienator  554
 
 ALIUM.................1
cancelled using the nemo plus juris ad  alium  transferre potest quam ipse habet rule, 628
 
 ALIVE.................1
was still  alive  his obligation for the payments in each of the years , and became 1924
 
 ALIÉNATION............3
found in the I.T.A. One of the differences is the use of the term  aliénation , found only in the 3078
I.T.A., the definition of  aliénation  in the T.A. is not exhaustive. We should therefore refer to 3080
L aliénation  nétant pas définie par la loi, on doit y appliquer le sens général de ce mot 3082
 
 ALIÉNÉS...............2
 aliénés . The Court held that they both should have the same meaning, whether the translation 1564
is disposes or  aliénés . 1566
 
 ALL-ENCOMPASSING......1
published in , favoured an  all-encompassing  tax res that would include any increase in 3540
 
 ALLARD................1
Author: Marie-Pierre  Allard  2
 
 ALLEGED...............1
not be applied? Is it not highly material that the very beneficiary of the  alleged  restitution chose 536
 
 ALLOCATE..............1
entitled under this law to ask that the Court  allocate  a fair and equitable share of the estate for 2432
 
 ALLOCATION............4
When the Civil Code was reformed, the special risk  allocation  regime applicable to conditional 378
. The  allocation  of fruits and revenues and the assumption of risks incident to property 384
Thus, in a conditional sale, the  allocation  of risks to the debtor of the obligation to deliver is no 416
from retroactivity, such as the  allocation  of risks. Moreover, they note that consequences usually 622
 
 ALLOTTED..............1
Where the condition is not fulfilled within the  allotted  time or when it becomes certain that it will 206
 
 ALLOW.................11
transfer of possession. This is because the property must be delivered to the buyer to  allow  for 876
Certain provincial statutes  allow  courts may make retroactive orders. Most common law 1150
with the Act read as a whole. The Act is not designed to  allow  the application of new facts that 2940
occur during a taxation year to a prior taxation year. To this end, it does not  allow  2940
did not, in this case,  allow  for the financial statements to be amended, and resubmitted to the 3238
 allow  this situation when it ruled in Dominion Engineering. 3380
The Agency justifies its position by arguing that the Act read as a whole, does not  allow  it to 3406
to  allow  the Agency to reassess and claim any amounts due in such instances. Moreover, the 3410
amended to  allow  the Agency to reassess a particular year, even if it falls outside the normal 3474
the risks and charges. But it would also be unfair not to  allow  the buyer to claim CCA for these 3484
be the legislators intent. At the very least, a clearly drafted Act would  allow  Quebec taxpayers 3596

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