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 PRIVILEGED............2
worlds two major legal systems, bijuralism places Canada in a  privileged  position within the 112
always be  privileged  since simplicity and concision may be lost, notably in long tax provisions. 382
 
 PRIVY.................1
The Honourable Stéphane Dion, President of the Queens  Privy  Council for Canada and 718
 
 PRIVÉ.................1
André Ouellette Mathieu Legris, La place du droit  privé  au sein des lois fédérales : 916
 
 PROBLEM...............3
emergence of new terminology in bijural provisions might present a  problem  for the Anglophone 396
mortgage: the second  problem  was one of semi-bijuralism: the English version of the 446
survivorship. This concept does not exist in civil law. In order to correct the  problem , the 452
 
 PROBLEMATIC...........1
ownership or beneficial ownership in the development of tax policy is  problematic . It is 388
 
 PROBLEMS..............6
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
It can readily be seen from these remarks that three types of  problems  are of concern in the 344
Brown, Mark Brender and Diane Bruneau have addressed such  problems  in their study of the 348
They have identified specific  problems  and attempts are made to develop equivalent concepts 350
Different drafting techniques can be used to correct harmonization  problems . In each case, the 364
These bijural records briefly explain the harmonization  problems  found in the legislative 418
 
 PROCEDURE.............1
stated by Professor Ziff to the rules of civil  procedure  that governed litigation at common law 198
 
 PROCEEDINGS...........6
 proceedings  that relate to any death or personal or bodily injury. 578
Canada, Senate,  Proceedings  of the Standing Senate Committee on Legal and 714
See Canada, Senate,  Proceedings  of the Standing Senate Committee on Legal and 886
 Proceedings  of the Standing Senate Committee on Legal and Constitutional Affairs, Issue 892
Faculty, Civil Law Section of the University of Ottawa in Canada, Senate,  Proceedings  of the 896
Canada, Senate,  Proceedings  of the Standing Senate Committee on Legal and 908
 
 PROCESS...............5
To better understand some of the issues that have to be addressed in the  process  of harmonizing 162
available will be to amend the law. Such a  process  can be both difficult and time consuming.172
its scope and  process  to the revision of federal legislation that took place in the late s to 324
harmonization  process : 344
chosen, section . was added so that the redrafting  process  does not give rise to any ambiguity 562
 
 PROCLAMATION..........1
under the Royal  Proclamation , . Canadian bijuralism dates back to the Quebec Act, 14
 
 PRODUCE...............2
may  produce  tax results in one province that are not desirable from a legislative or policy 156
consequences, it is imperative that this legislation be applied so as to  produce  equal tax 328
 
 PRODUCING.............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
 
 PRODUCT...............1
property into its  product . The beneficiary has a similar right against anyone to whom the trustee 256
 
 PROFESSOR.............8
correct terminology is used when referring to them.  Professor  Nicholas Kasirer, while 82
stated by  Professor  Ziff to the rules of civil procedure that governed litigation at common law 198
 Professor  David Duff analyzes the new interpretation rules and their impact on Canadian tax 614
ITA with Quebec civil law.  Professor  Catherine Brown analyzes the concept of beneficial 616
As will be seen in  Professor  David Duffs article, our courts have played an important role in 640
The issue of highlighting terms was raised, among others, by  Professor  Claude Fabien of 882
This issue was also raised by  Professor  Fabien while appearing before the Standing Senate 890
To that effect see the evidence presented by  Professor  Alain-François Bisson of the Law 896
 
 PROFIT................1
no one may  profit  from his or her crime. Mrs. St-Hilaire applied to the Federal Court Trial 514
 
 PROGRAM...............11
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
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
Thereafter, in , the  Program  for the Harmonization of Federal Legislation with the Civil 76
Law of Quebec was implemented. This  program  is also a consequence of the coming into 78
. The Harmonization  Program  and its Objectives 312
The Harmonization  Program  is administered by the Legislative Services Branch of the 320
Department of Justice. This  Program  purports to systematically review the existing body of 322
McLellan, former Minister of Justice, described the purpose of the Harmonization  Program  in 332
and Europe  Program  to Harmonize Federal Legislation with the Civil Law of the Province of 938
The Department of Justice Canada established the  Program  of Research Contracts on 972
this  program  is also to promote the development of expertise in Canadian bijuralism among law 974
 
 PROGRAMS..............1
symmetrynecessary to administer coherently federal policies and  programs  sometimes calls for 148
 
 PROGRESS..............4
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
.  Progress  to Date and Legislative Amendments 428
have been completed and others are in  progress . The first reports, most of which have recently 604
currently in  progress  namely on the concept of indefeasibly vested dévolution irrévocable 610
 
 PROJECT...............1
The harmonization  project  therefore represents an opportunity to correct previous oversights, 340
 
 PROJECTS..............2
A number of research  projects  on various issues pertaining to Canadian bijuralism in the tax field 604
Students are also invited annually to participate in harmonization research.  Projects  are 610
 
 PROMISE...............1
in Quebec but also the  promise  of a common law culture in French outside of Quebec such that 104
 
 PROMISSORY............1
See Constitution Act, , subsections () Bills of Exchange and  Promissory  Notes, 698
 
 PROMOTE...............1
this program is also to  promote  the development of expertise in Canadian bijuralism among law 974
 
 PROPERTY..............108
, which recognized that in matters of  property  and civil rights (private law), the civil law 16
tradition, inspired by British common law, applied in such matters of  property  and civil rights 18
outside of Quebec. Conversely, in matters other than  property  and civil rights (public law), the 18
where provinces have maintained exclusive jurisdiction over matters of  property  and civil 22
anything affecting  property  and civil rights, and the common law as it existed in England at the 40
Matters of Controversy, relative to  Property  and Civil Rights, Resort shall be had to the Laws 44
that provincial legislatures have exclusive jurisdiction over matters of  property  and civil rights. 132
private law terms and concepts such as mortgage,  property , trust and leases, without defining 134
having title to  property  at common law and title at equity. This duality stems from the 176
.  Property  Law 184
In the field of  property  law, the differences between both systems have given rise and continue 186
acquisition and disposition of  property . Listing the characteristics pertaining to the nature and 188
Civil law has a very Cartesian approach to the law of  property . Article of the Civil Code 192
states that  Property , whether corporeal or incorporeal, is divided into immovables and 192
movables. The Civil Code then lists the  property  that is or is deemed immovable and all 194
other  property , if not qualified by law, is deemed movable. 194
By comparison, at common law,  property  is fundamentally divided between real property and 196
By comparison, at common law, property is fundamentally divided between real  property  and 196
personal  property . The rules pertaining to the classification of property owe their origin, as 196
personal property. The rules pertaining to the classification of  property  owe their origin, as 196
these labels have remained. A real action could be undertaken with regards to  property  for 200
which the return of the land could be ordered. This  property  was eventually designated as 200
real  property . The personal action was originally one for which only damages could be 202
awarded. Personal  property  eventually became the label ascribed to the property subject to 202
awarded. Personal property eventually became the label ascribed to the  property  subject to 202
nevertheless considered as a personal  property . 204
 Property  under civil law is thus qualified pertaining to its nature whereas it is the form of action 206
In civil law, ownership is central. Effectively, there is always just one right of  property  on 208
movables or immovables. Regardless of whether  property  is movable or immovable, one will 210
always try to answer the question: Who owns or has title to the  property ? At common law, 210
on the other hand, ones analysis will depend on whether the  property  is personal or real. One 212
can own personal  property  in a manner much similar to the civil law conception of property 212
can own personal property in a manner much similar to the civil law conception of  property  212
law. With regards to real  property , the law historically developed around the idea that land 214
Possession is an essential feature of the law of real  property . At common law, ones inquiry will 218
..  Property : a Conceptual Difference 220
At common law,  property  is composed of and can be fragmented into various rights and 222
the same  property . Such a coexistence of titles is not possible in civil law since the 224
the  property  but rather involve a separation of the attributes of ownership: usus, fructus and 228
certain time, of  property  owned by another as ones own, subject to the obligation of preserving 232
its substance whereas a right of use is the right to enjoy the  property  of another for a time 232
A trust is an equitable obligation binding a person (who is called a trustee) to deal with  property  248
The trust involves a split or duality in the transferred  property s title; the trustee having the legal 252
title to the  property  while the beneficiary or beneficial owner, holds the equitable title to the 252
same  property . The equitable obligation is associated with the idea of a conscience or 254
moral duty owed to the beneficiary. It is so strong as to allow tracing of the  property  in the 254
 property  into its product. The beneficiary has a similar right against anyone to whom the trustee 256
has transferred the  property , provided the transferee was a volunteer or took with notice of the 258
theory of  property  to say the least. Before , better known civil law institutions such as 264
 property . The trust became an autonomous patrimony. Once the settlor has transferred 268
 property  to the trust and the trustee has accepted to hold and administer it, nobody owns the 268
 property  anymore, neither the trustee nor the beneficiary. There is no duality of property as 270
property anymore, neither the trustee nor the beneficiary. There is no duality of  property  as 270
in common law. The trustee never becomes the owner of the  property  at law and although the 270
 property . Thereafter, the trustee only has duties and obligations and the beneficiary has 272
fields related to the law of  property  such as mortgages and leases. 276
stems from the fundamental differences in  property  law. From a common law point of 280
 property . The rules pertaining to the lease are perfectly integrated with the civil law 294
conception of  property . The lessor remains at all times owner of the premises. The lessee has 296
payment of the rent. He has no real right on the  property , only a right of claim. Upon 298
termination of the lease, the lessee simply surrenders the  property  to the lessor in the condition 298
he received it. The lease in no way affects ownership of  property , only its enjoyment.300
to the ownership of the  property  being mortgaged. Except for common law provinces wherein 302
 property  to the mortgagee (creditor). In all common law provinces, if personal property is 304
property to the mortgagee (creditor). In all common law provinces, if personal  property  is 304
mortgaged (chattel mortgage), legal title to the  property  is always conveyed to the mortgagee 306
(creditor) as security for the repayment of the loan. In both cases, legal title to the  property  306
 property . The hypothecary creditor only has a charge, a real right on the property. 310
property. The hypothecary creditor only has a charge, a real right on the  property . 310
Interpretation Act and to approximately fifty federal statutes in matters of  property  law, 430
hypothec beside mortgage. In addition, we now find the double real  property  or 460
complementarity of federal law with the law of the provinces respecting  property  and civil 476
law with respect to  property  rights. The section reads as follows: 482
law of  property  and civil rights in Canada and, unless otherwise provided by law, if in 484
forming part of the law of  property  and civil rights, reference must be made to the rules, 486
 property  and civil rights in Canada, a premise of Canadian bijuralism. In addition, the provision 490
Thus, a taxpayer who comes across a double such as mortgage or hypothec or real  property  564
immovable for the Province of Quebec and mortgage and real  property  for all other 566
licence ( property  law perspective) as used in the Excise Tax Act. 608
It is mainly in the fields of the law of  property  and the law of trusts that this duality creates 738
Barbara Pierre, Classification of  Property  and Conceptions of Ownership in Civil and 740
A.H. Oosterhoff W.B. Rayner, Anger and Honsberger Law of Real  Property , Vol. , 742
Article CCQ states that All other  property , if not qualified by law, is movable.748
Bruce Ziff, Principles of  Property  Law, rd ed. (Scarborough, ON: Carswell, ), .750
Personal  property  is not subject to the doctrines of estates and tenures and are thus 756
other lawful purposes within the limits permitted by law; he may also deliver over his  property  780
charged as a mere trustee, to administer the  property  and to employ it or deliver it over in 784
retain the  property  in the event of the lapse of the ulterior disposition, or of the impossibility of 786
applying such  property  to the purposes intended, unless the testator has manifested his intention 788
to that effect. The  property  in such cases passes to the heir or the legatee who receives the 788
 property  from his patrimony to another patrimony constituted by him which he appropriates to a 804
Article CCQ: The trust patrimony, consisting of the  property  transferred in trust, 806
relating to the  property  of which it is composed are drawn up in his name; he has the exercise of 812
A trustee acts as the administrator of the  property  of others charged with full 814
by the lessor. The lease was thus classified as personal  property . Over time, it could no longer 820
Robert Megarry William Wade, The Law of Real  Property , th ed., (London: Stevens 824
M-Jane Mossman and William F. Flanagan,  Property  Law: Cases and Commentary, 828
lessee, in return for rent, with the enjoyment of a movable or immovable  property  for a certain 832
The lessor is bound to deliver the leased  property  to the lessee in a good state of repair in all 836
respects and to provide him with peaceable enjoyment of the  property  throughout the term of 836
He is also bound to warrant the lessee that the  property  may be used for the purpose 838
for which it was leased and to maintain the  property  for that purpose throughout the term of the 840
Article CCQ: The lessee is bound to pay the agreed rent and to use the  property  with 842
Upon termination of the lease, the lessee is bound to surrender the  property  in the condition in 846
the  property  or superior force. 848
The condition of the  property  may be established by the description made or the 848
received the  property  in good condition at the beginning of the lease. 850
Personal  Property , rd Edition (Toronto, ON: R.M. Willes Chitty) ; Sands v. Standard Ins. 864

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