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 PROPOSALS.............2
harmonization  proposals  for inclusion in a second harmonization bill. Public consultations are 432
planned for January on this second set of general harmonization  proposals .434
 
 PROPOSED..............1
The Department of Justice will examine the various solutions  proposed  in these reports with the 618
 
 PROPRIETOR............1
 proprietor  subject to deliver over, rather than that of a mere executor or administrator, does not 786
 
 PROVIDE...............4
Sections . and . of the Interpretation Act constitute the cornerstone and  provide  the rules 472
tax policy principles of equity or of neutrality in taxation. That tax legislation must  provide  for an 624
lease is a contract by which a person, the lessor, undertakes to  provide  another person, the 830
respects and to  provide  him with peaceable enjoyment of the property throughout the term of 836
 
 PROVIDED..............8
federal definitions or specific federal rules are  provided , they often refer, in varying degrees, to 152
that apply in civil law are those expressly  provided  for in the Civil Code or other statutes.184
has transferred the property,  provided  the transferee was a volunteer or took with notice of the 258
common law partner  provided  in the I.T.A. offer good examples. By defining its own rules 378
law of property and civil rights in Canada and, unless otherwise  provided  by law, if in 484
the benefits  provided  in the PSSA. 516
Unless otherwise  provided  by law, when an enactment contains both civil law and common law 556
specific rules are  provided  by law. This means that federal tax provisions cannot be interpreted 630
 
 PROVIDES..............4
As noted earlier, the division of legislative powers under the Constitution Act,  provides  130
legal infrastructure of the federal legislation. Provincial private law  provides  the suppletive law 138
Article CCQ  provides  that ownership may be in various modes and dismemberments. 226
Article CCQ  provides  that the: 830
 
 PROVINCE..............37
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
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
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
and Quebec civil law, the same rules apply with regards to any other  province .56
(civil law or common law) of their  province  or territory; 76
provincial law. While the content of provincial law may vary from  province  to province, the 128
provincial law. While the content of provincial law may vary from province to  province , the 128
such terms and concepts, they take the meaning that applies in the private law of the  province  in 134
heterogeneous as some of its rules vary from one  province  to the other. The lack of 146
may produce tax results in one  province  that are not desirable from a legislative or policy 156
solely to harmonization with the civil law of the  Province  of Quebec of three concepts: executor, 440
interpreting an enactment it is necessary to refer to a  province s rules, principles or concepts 486
principles and concepts in force in the  province  at the time the enactment is being applied.488
of the  province  that fills the void. In short, the civil law applies in Quebec to any federal 532
must be interpreted in light of the private law of the  province  in which the provision is to be 536
civil law terminology or meaning is to be adopted in the  Province  of Quebec and the common 558
immovable for the  Province  of Quebec and mortgage and real property for all other 566
irrespective of the  province  in which income is earned, is not in dispute at all. What is in issue, 626
legislation must be more civil law friendly for purposes of its application in the  Province  of 634
provinces due for example to the specific statute law applicable in a given  province , such 638
provincial private law will be that the tax treatment will differ depending on the  province  of 644
the  Province  of Quebec and includes the territories. 674
Canada, in The Harmonization of Federal Legislation with the Civil Law of the  Province  676
with the Civil Law of the  Province  of Quebec and Canadian Bijuralism. Second 680
 Province  of Quebec and Canadian Bijuralism. Second Publication, Booklet , (Ottawa: 686
Harmonization of Federal Legislation with the Civil Law of the  Province  of Quebec and 688
the Civil Law of the  Province  of Quebec and Canadian Bijuralism. Second Publication, 704
the  Province  of Quebec and Canadian Bijuralism. Second Publication, Booklet , 710
of the  Province  of Quebec and Canadian Bijuralism. Second Publication, Booklet , 720
with the Civil Law of the  Province  of Quebec and Canadian Bijuralism. Second 724
Harmonization of Federal Legislation with the Civil Law of the  Province  of Quebec and 736
la  province  de Québec, (Montréal : Wilson Lafleur, ), -. 778
the Civil Law of the  Province  of Quebec and Canadian Bijuralism. Second 798
A First Act to harmonize federal law with the civil law of the  Province  of Quebec 920
and Europe Program to Harmonize Federal Legislation with the Civil Law of the  Province  of 938
of Federal Legislation with the Civil Law of the  Province  of Quebec and Canadian 940
Federal Legislation with the Civil Law of the  Province  of Quebec and Canadian 944
 
 PROVINCES.............16
institution of trust and the concept of ownership vary considerably as between the common law  provinces  private law and Quebecs civil law regime. Moreover, even between common 6
where  provinces  have maintained exclusive jurisdiction over matters of property and civil 22
that of the other  provinces  to keep their common law regime of British origin. While the federal 24
 provinces  this backdrop or infrastructure is the general common law but in Quebec the 140
The important differences that exist in our legal traditions and in the private law of the  provinces  156
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
complementarity of federal law with the law of the  provinces  respecting property and civil 476
law terminology or meaning is to be adopted in the other  provinces . 558
 provinces . The redrafting of certain federal enactments being one of the harmonization tools 562
Canadian  provinces . This interpretive approach was recently approved by the Supreme Court 568
extends not only to Quebec civil law but also to the private law of the other  provinces  and 636
 provinces  due for example to the specific statute law applicable in a given province, such 638
general common law in the other  provinces . Sometimes, the consequence of respecting 644
The expression common law  provinces  is used to refer to all Canadian provinces except 674
The expression common law provinces is used to refer to all Canadian  provinces  except 674
 
 PROVINCIAL............52
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
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
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
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
private law rules, the bulk of Canadian private law is in  provincial  law. 26
from  provincial  private law include such matters as the concepts of ownership, partnership, 28
. Complementarity and Dissociation: The Interplay of Federal and  Provincial  120
relationships between federal and  provincial  private law. As such, federal legislation does not 122
often stand alone and depends on  provincial  private law for meaning. 124
 provincial  law. While the content of provincial law may vary from province to province, the 128
provincial law. While the content of  provincial  law may vary from province to province, the 128
validity of any such  provincial  law, in large measure, depends of s. of the Constitution Act 128
that  provincial  legislatures have exclusive jurisdiction over matters of property and civil rights. 132
Most of Canadas private law is  provincial . Therefore, where federal legislation refers to 132
which the provision is being applied.  Provincial  law thus is in symbiosis with federal legislation 136
and gives it meaning. This interaction of federal and  provincial  legislation is called 136
complementarity.  Provincial  private law, in this relationship, can be viewed as the backdrop or 138
legal infrastructure of the federal legislation.  Provincial  private law provides the suppletive law 138
type of relationship is called dissociation. For example,  provincial  family law is often 146
 provincial  private law infrastructure than to reinvent it in every federal statute. Thus, even where 150
 provincial  private law rules and concepts. The interpretation of federal legislation requires an 152
awareness of the differences in our legal traditions and of the diversity in our  provincial  private 154
legislation and  provincial  private law. It should be emphasized that the harmonization of tax 316
civil law when they refer to  provincial  private law rules and concepts. This revision is similar in 324
 provincial  private law. 380
bijuralism and to consecrate the principle of the complementarity of federal law and  provincial  482
codifies the principle of complementarity of  provincial  private law. We emphasize that the 490
to all  provincial  private law, including general common law and provincial statutory law. In 492
to all provincial private law, including general common law and  provincial  statutory law. In 492
to  provincial  private law terms used in federal legislation. 494
jurisdiction of the federal government fully independent of  provincial  law while the second 500
one argued for the recognition of the complementary nature of  provincial  private law in matters 502
A new debate ensued from this recognition: does  provincial  private law complete only federal 504
 provincial  private law where the former is silent on the meaning of a concept.522
Justice Décary rejected the argument that  provincial  private law is to complete only federal 524
case) or relies upon  provincial  private law to complete it, then reference is to be made to 550
 provincial  private law. 550
legislation which relies upon complementary  provincial  law reflect Canadas bijural and bilingual 584
complementarity of  provincial  private law with federal legislation, provincial private law 628
complementarity of provincial private law with federal legislation,  provincial  private law 628
It should be emphasized further that the requirement of compatibility with  provincial  private law 636
territories. If there are material differences in the  provincial  private law of common law 638
 provincial  private law will be that the tax treatment will differ depending on the province of 644
of  provincial  private law and the equality of the civil law and the common law are also important 652
legislator may always derogate from  provincial  private law and specifically set out its own rules, 654
where the application of  provincial  private law leads to differences in tax treatment. The issue is 654
not one of choosing between tax equity and the respect of  provincial  legal diversity but 656
 provincial  private law will complete it. 658
Interpretation Act now clearly and broadly set the requirement of compatibility with  provincial  660
and uniqueness of the concepts and principles of each legal system. The fact that  provincial  982

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