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 APPLICABLE............6
sealed the fate of the two legal systems that were to govern the  applicable  law in Quebec: the 38
with and  applicable  within each of our two legal traditions in both of our official languages.108
rule using, side by side, the terminology  applicable  to each legal system. This technique will not 382
common law terms, the former will be  applicable  in Quebec and the latter in the other 560
found in paragraph (a) of the State Immunity Act was  applicable . This exception 574
provinces due for example to the specific statute law  applicable  in a given province, such 638
 
 APPLICATION...........19
This article is followed by four in depth articles studying problems in the  application  of the Income Tax Act arising from differences in provincial private law. For example, the 4
law provincial jurisdictions, significant differences may arise as a result of variations in provincial statutes dealing with such matters as what might constitute a charitable activity in the province or who might be viewed as residing in the province. Such diversity in provincial private law is, as will be seen in the articles that follow, susceptible of producing significant differences in the  application  of federal legislation tax and other from one province to the other. 6
that such concepts or matters may call for a different meaning and  application  from one legal 30
tradition to the other or worse that the concepts might have no meaning or  application  in the 32
meaning and  application  throughout Canada whether the federal legislation is applied in the 34
changes have an impact on the  application  in Quebec of federal acts and regulations. 80
backdrop is the Civil Code of Québec and civil law principles of general  application .142
 application  of common law rules is inadequate, it is possible to obtain certain equitable 174
and civil law that may affect the  application  of federal legislation throughout Canada.312
 application  and enforcement of federal tax legislation. 320
of creating differences in  application  from one system to the other. 374
can be used in the interpretation or  application  of harmonized enactments. The usefulness 422
Income Tax  Application  Rules. 456
 application  in the unique civil law environment of Quebec. Comparative law analyses are being 468
Justice Blais allowed Mrs. St-Hilaires  application  and ordered the Treasury Board Secretariat 518
legislation must be more civil law friendly for purposes of its  application  in the Province of 634
 application . In a minority of cases, however, the courts have refused to apply the civil law in 646
Quebec, favouring an interpretation resulting in uniformity of  application , admittedly, for tax 646
where the  application  of provincial private law leads to differences in tax treatment. The issue is 654
 
 APPLIED...............16
tradition, inspired by French civil law,  applied  in Quebec in the same way that the common law 16
tradition, inspired by British common law,  applied  in such matters of property and civil rights 18
common law tradition has  applied  and continues to apply in Quebec and outside Quebec. 20
meaning and application throughout Canada whether the federal legislation is  applied  in the 34
which the provision is being  applied . Provincial law thus is in symbiosis with federal legislation 136
will have to determine which of the rules found in the Civil Code is to be  applied . Because no 170
consequences, it is imperative that this legislation be  applied  so as to produce equal tax 328
principles and concepts in force in the province at the time the enactment is being  applied .488
no one may profit from his or her crime. Mrs. St-Hilaire  applied  to the Federal Court Trial 514
Division for a declaratory judgment that civil law rules  applied  and that these rules entitled her to 516
Quebec, no rule  applied  to disallow Mrs. St-Hilaires claim. The Federal Court of Appeal 520
but the fact, quite simply, that the federal enactment in a given case must be  applied  to situations 528
 applied : 536
initially  applied  to cases of any death or personal injury. Paragraph (a) was amended by the 576
a marking system would have to be  applied  consistently and failure to mark a legal concept 904
achieve one rule to be  applied  uniformly across Canada; this requires respect for the character 980
 
 APPLIES...............5
legislation ensure that it  applies  to Francophones and Anglophones alike and also applies 64
legislation ensure that it applies to Francophones and Anglophones alike and also  applies  64
such terms and concepts, they take the meaning that  applies  in the private law of the province in 134
the Torrens system of land titles registration  applies , a mortgage conveys legal title to real 304
of the province that fills the void. In short, the civil law  applies  in Quebec to any federal 532
 
 APPLY.................16
common law tradition has applied and continues to  apply  in Quebec and outside Quebec. 20
source in order to  apply  a federal statute. The Parliament of Canada may enact private law 50
and Quebec civil law, the same rules  apply  with regards to any other province.56
legislation  apply  equally and coherently across the country in both linguistic versions and in both 60
adequately bridged with specific provisions if federal tax legislation is to  apply  effectively and 160
that  apply  in civil law are those expressly provided for in the Civil Code or other statutes.184
the concept of ownership does not neatly  apply  to a leasehold estate, because neither the 288
adapted to the civil law tradition, if tax laws are to  apply  effectively in Quebec. Catherine 346
preferable to use more neutral terms and concepts that  apply  readily to both legal traditions or, 388
rights. What is more, there are no rules of interpretation to guide those required to  apply  bijural 476
principle of complementarity is cast very broadly so to  apply  not only in regards to civil law but 492
private legislation or does it  apply  in all cases regardless of the qualification of an act as private 506
believe the decision will  apply  to all harmonized enactments. 570
principles, rules and concepts should  apply  in interpreting federal tax legislation unless other 630
application. In a minority of cases, however, the courts have refused to  apply  the civil law in 646
private law. These rules not only  apply  to the traditional interpreters like the courts but also to 660
 
 APPLYING..............2
The purpose of this article is to give a general overview of the Harmonization Program and its progress as of October . Before exploring some of the differences in the provincial private law and their potential impact on federal tax legislation, it would be useful to give background information on the duality of our legal system and on the particular interaction between federal law and provincial private law in Canada. Next we will give a broad overview of the most important differences between the common law tradition and the civil law tradition in order to illustrate the challenge at hand in  applying  federal tax legislation fairly and efficiently. Also we will briefly explain the Harmonization Program, its objectives and techniques, and report on the harmonization work done thus far.4
 applying  such property to the purposes intended, unless the testator has manifested his intention 788
 
 APPORTIONMENT.........1
 Apportionment  (in percentage) of Political Entities according to their Legal System, 726
 
 APPROACH..............4
Civil law has a very Cartesian  approach  to the law of property. Article of the Civil Code 192
) semi-bijuralism: this drafting  approach , which consists in using exclusively common 352
Canadian provinces. This interpretive  approach  was recently approved by the Supreme Court 568
This interpretative  approach  must now be reconsidered following the adoption of the principle 648
 
 APPROACHES............1
often incompatible institutions, rules and  approaches . Yet it is necessary that federal tax 60
 
 APPROPRIATE...........4
version, is no longer  appropriate  to address the four legal audiences (common law and civil law 354
choice of the most  appropriate  solution will depend on the situation, the structure of the 366
common law terminology? Would it be  appropriate  to create a lexicon of private law 402
 appropriate  in French for both common law and civil. 450
 
 APPROPRIATES..........1
property from his patrimony to another patrimony constituted by him which he  appropriates  to a 804
 
 APPROPRIATION.........2
constitutes a patrimony by  appropriation , autonomous and distinct from that of the settlor, 808
 appropriation . 814
 
 APPROVED..............1
Canadian provinces. This interpretive approach was recently  approved  by the Supreme Court 568
 
 APPROXIMATELY.........1
Interpretation Act and to  approximately  fifty federal statutes in matters of property law, 430
 
 AREA..................1
Another  area  in which both legal systems are very different is the law of trusts. In common law, 244
 
 AREAS.................1
Tax law has been identified as one of the key  areas  requiring harmonization along with 326
 
 ARGUED................3
one  argued  for the recognition of the complementary nature of provincial private law in matters 502
Mr. Schreiber  argued  that adding bodily injury to death or personal injury had broadened 578
 argued  that the insertion of bodily injury was intended to ensure that the wording used in 582
 
 ARGUMENT..............1
Justice Décary rejected the  argument  that provincial private law is to complete only federal 524
 
 ARISE.................1
law provincial jurisdictions, significant differences may  arise  as a result of variations in provincial statutes dealing with such matters as what might constitute a charitable activity in the province or who might be viewed as residing in the province. Such diversity in provincial private law is, as will be seen in the articles that follow, susceptible of producing significant differences in the application of federal legislation tax and other from one province to the other. 6
 
 ARISING...............1
This article is followed by four in depth articles studying problems in the application of the Income Tax Act  arising  from differences in provincial private law. For example, the 4

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