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 ARRESTED..............1
Mr. Schreiber had been  arrested  and detained for one week further to a request from 572
 
 ARTHUR................1
John Augustus Barron and  Arthur  Henry OBrien, Barron and OBrien on Chattel 862
 
 ARTICLE...............26
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
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
affecting the public law.  Article  VIII of The Quebec Act, , which prescribed that in all 42
Civil law has a very Cartesian approach to the law of property.  Article  of the Civil Code 192
 Article  CCQ provides that ownership may be in various modes and dismemberments. 226
As will be seen in Professor David Duffs  article , our courts have played an important role in 640
 Article  CCQ states that All other property, if not qualified by law, is movable.748
 Article  CCQ. 764
 Article  CCQ. 766
 Article  CCQ. 766
 Article  CCQ. 768
 Article  CCQ. 768
For a more detailed discussion, see the  article  by Catherine Brown published hereafter in 772
 Article  Civil Code of Lower Canada (herein referred to as CCLC) stated that A 778
imposed upon his heirs or legatees.  Article  CCLC stated that The legatee who is 782
(SRQ ,  article  ) after having been first introduced in a distinct act Acte 792
 Article  CCQ: A trust results from an act whereby a person, the settlor, transfers 804
 Article  CCQ: The trust patrimony, consisting of the property transferred in trust, 806
 Article  CCQ: 810
 Article  CCQ: While the trust is in effect, the beneficiary has the right to require, 816
 Article  CCQ provides that the: 830
 Article  CCQ: 834
 Article  CCQ: The lessee is bound to pay the agreed rent and to use the property with 842
 Article  CCQ: 844
This portion of the  article  pertaining to the mortgagehypothec was written by Me Joseph 852
 Article  CCQ. 868
 
 ARTICLES..............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
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
See for example  articles  and CCQ. 746
 Articles  to CCQ. 748
 Articles  CCQ. 770
 Articles  a to n were added to the Civil Code of Lower Canada on January st 790
 
 ARTICULATED...........1
 articulated  around unijuralisms or legal concepts that have no equivalent in the civil law 386
 
 ARTICULATION..........1
should also inform and influence the development and  articulation  of tax policy and of tax 662
 
 ASCRIBED..............1
awarded. Personal property eventually became the label  ascribed  to the property subject to 202
 
 ASSENTED..............4
Harmonization Act, No. ), SC , c. , which was  assented  to on May th, and 924
Income Tax Amendments Act, , SC , c., which was  assented  to on June 926
SC , c. , which was  assented  to on October th, . 932
Ships Stores, SC , c. , which was  assented  to on June th, . 934
 
 ASSIST................1
Canadian bijuralism to  assist  the Department in its harmonization work deriving from the 972
 
 ASSISTANCE............1
 assistance  with research and the revision of this paper. The opinions expressed are those of the 670
 
 ASSOCIATE.............2
Mario Dion,  Associate  Deputy Minister, Civil Law and Corporate Management, 702
 Associate  Deputy Minister, Civil Law and Corporate Management, Department of Justice 706
 
 ASSOCIATED............1
same property. The equitable obligation is  associated  with the idea of a conscience or 254
 
 ASSOCIATION...........1
planification fiscale et successorale, Montréal,  Association  de planification fiscale et 918
 
 ASSUMPTION............1
Quebec,  Assumption  of Complementarity and Methodological Issues, in The Harmonization 938
 
 ASYMMETRY.............1
perspective (undesirable  asymmetry ). In keeping with the principle of complementarity these 158
 
 ATTEMPT...............1
The Court then analysed the French version in its  attempt  to give meaning to the terminology 594
 
 ATTEMPTS..............1
They have identified specific problems and  attempts  are made to develop equivalent concepts 350
 
 ATTORNEY..............4
The Supreme Court agreed with the  Attorney  Generals interpretation of the provision. The 586
St-Hilaire v. Canada ( Attorney  General), FC (C.A.). 700
Justice and Deputy  Attorney  General of Canada, Evolution of Legal Systems, Bijuralism and 722
Karlheinz Schreiber v. Canada ( Attorney  General), SCC . 964
 
 ATTRIBUTES............3
the property but rather involve a separation of the  attributes  of ownership: usus, fructus and 228
separation of the  attributes  of ownership; the right of ownership remains whole. In a co-236
ownership, the exercise of the  attributes  of ownership on a subject matter is however 238
 
 AUDIENCE..............1
this concept in tax legislation and underlines the difficulties for the civil law  audience .618
 
 AUDIENCES.............5
the four legal  audiences  of this country has led to the adoption in of the Policy on 68
formally recognizes that it is imperative that the four Canadian legal  audiences  (Francophone 70
Currently, federal legislation covers only partially the four Canadian legal  audiences . Anne 330
version, is no longer appropriate to address the four legal  audiences  (common law and civil law 354
all legal  audiences  it would be inconsistent to distinguish one legal concept from another by 408
 
 AUGUSTUS..............1
John  Augustus  Barron and Arthur Henry OBrien, Barron and OBrien on Chattel 862
 
 AURORA................1
nd ed., ( Aurora , ON: Canada Law Books, ), at -. 744
 
 AUTHORITATIVE.........2
Both the common law and the civil law are equally  authoritative  and recognized sources of the 484
This provision states that civil law and common law are equally  authoritative  in matters of 488
 
 AUTHORITY.............1
give French and English equal  authority  as expressions of legislative text and the coexistence of 100
 
 AUTHORS...............3
 Authors : Marc Cuerrier, Sandra Hassan, Marie-Claude Gaudreault 2
The  authors  wish to thank Me André Ouellette, Me Martin Lamoureux and all other members 668
 authors  and do not necessarily correspond to the Department of Justice Canada position on any 670
 
 AUTONOMOUS............2
property. The trust became an  autonomous  patrimony. Once the settlor has transferred 268
constitutes a patrimony by appropriation,  autonomous  and distinct from that of the settlor, 808
 
 AVAILABLE.............9
 available  will be to amend the law. Such a process can be both difficult and time consuming.172
Affairs, the Department of Justice made these bijural terminology records  available . 418
Constitutional Affairs, Issue Evidence, Ottawa, March , ( available  on the web at 714
University of Ottawa ( available  on the web at http:www.uottawa.caworld-legal-systemseng-728
Canadian Bijuralism, Montreal (Quebec), November . ( available  on the web at 874
Constitutional Affairs, Issue Evidence, Ottawa, March st, ( available  on the web at 886
Evidence, Ottawa, March st, ( available  on the web at 892
Ottawa, March st, ( available  on the web at 898
Constitutional Affairs, Issue Evidence, Ottawa, March ( available  on the web at 910
 
 AVOIDING..............1
no  avoiding  the fact that a federal statute, albeit one characterized as public law, that refers to a 544
 
 AVOIDS................1
and concepts the legislator  avoids , in whole or in part, references to and potential differences in 378
 
 AWARDED...............1
 awarded . Personal property eventually became the label ascribed to the property subject to 202
 
 AWARENESS.............1
 awareness  of the differences in our legal traditions and of the diversity in our provincial private 154
 
 BACKDROP..............3
complementarity. Provincial private law, in this relationship, can be viewed as the  backdrop  or 138
provinces this  backdrop  or infrastructure is the general common law but in Quebec the 140
 backdrop  is the Civil Code of Québec and civil law principles of general application.142
 
 BACKGROUND............1
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

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