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 ALTERNATELY...................1
Thus, for the purposes of our study, we will use the term licence in English and  alternately  the 242
 
 ALTERNATIVE...................2
the only  alternative  to a perpetual licence is an instant termination of the respondents' 468
all the essential elements for the formation of a contract of lease are present or, in the  alternative , 2788
 
 ALTERNATIVELY.................1
contract will be relied on before trespass.  Alternatively , the licensor could rely on article 2780
 
 ALTERS........................1
licence properly passeth no interest, nor  alters  or transfers property in anything, but only makes 246
 
 AMBIGUITY.....................1
be placed on the private law definitions even though this creates some  ambiguity . That is why 2712
 
 AMEND.........................5
In light of that situation, Parliament decided in to end the debate and  amend  1290
 amend  certain Acts in order to ensure that each language version takes into account the 2852
 amend  certain Acts in order to ensure that each language version takes into account the 2854
with the civil law of the Province of Quebec and to  amend  certain Acts in order to ensure 3694
and to  amend  certain Acts in order to ensure that each language version takes into 3718
 
 AMENDED.......................11
Paragraph (f) has been  amended  twice by Parliament since the introduction of the E.T.A. in 1192
In , paragraph (f) was  amended  to exempt only the supply of real property by 1474
Income Tax Act, R.S.C. , th Supp., c., as  amended . 2846
Excise Tax Act, R.S.C. , c. E-, as  amended . 2848
Act respecting the Québec sales tax, R.S.Q., c. T-., as  amended . 2860
R.S.C. , c. E-, as  amended  (hereinafter also the Act). 3168
a) R.S.Q., c. T-., as  amended  (hereinafter A.Q.S.T.) 3452
 Amended  by S.C. , c. , subs. (). 3468
R.S.C. , th Supp., c., as  amended . 3630
paragraph (f) be  amended  to make all supplies of real property by way of licence taxable. 3674
R.S.C., c. I-, as  amended  by Bill S-, A First Act to harmonize federal law 3694
 
 AMENDMENT.....................21
... Paragraph (f) before the legislative  amendment  32
... Paragraph (f) since the legislative  amendment  32
The first legislative  amendment  dates back to , when it was proposed to make all 1198
have already seen. Before the  amendment , the distinction between a lease and a licence did not 1210
this point and better understand the source of the  amendment , we will look at Attorney 1216
granted by the parties' agreement. The  amendment  was thus directed particularly at supplies of 1294
 amendment  turned out to be insufficient to ensure that paragraph (f) of Part VI of 1308
Parliament proposed a second legislative  amendment  to paragraph (f) in . Thus, for 1320
Fortunately, this  amendment , which added the qualifier where the period throughout 1328
However, this legislative  amendment  resolves only part of the inequity problem. As we have 1340
... Paragraph (f) before the legislative  amendment  1348
The legislative  amendment  confirmed that interpretation and cast aside Stone J.A.'s 1368
... Paragraph (f) since the legislative  amendment  1372
Since the legislative  amendment  eliminating the words similar arrangement from 1372
 amendment  applied to supplies of real property made after September , . 1478
However, even after the  amendment , the problem raised in the Metropolitan Toronto Hockey 1478
That was why another  amendment  to paragraph (f) was proposed in the Notice of Ways and 1492
This latest  amendment  applies retroactively to supplies of real property made after 1498
paragraph (f) of Part VI of Schedule V of the E.T.A. since the legislative  amendment , 2522
occurred with the legislative  amendment . The use of the expression lease, licence or 2816
Hence the application of paragraph (f) before the  amendment , that is, for 3474
 
 AMENDMENTS....................6
.. Legislative  amendments  to paragraph (f) of Part VI of Schedule V 30
authorities' various interpretations of paragraphs (f), two legislative  amendments  enable us to 1190
.. Legislative  amendments  to paragraph (f) of Part VI of Schedule V 1192
 amendments  to the provision thus made it possible to provide a partial answer to the above 1472
 Amendments  to the GST Introduced (September , ). 3116
 Amendments  to the GST Introduced (Ottawa: Government Publications, September , 3470
 
 AMERICAN......................2
Re British  American  Oil Co. Ltd. v. De Pass, in which the Court once again had to 716
Re British  American  Oil v. De Pass, O.R. , D.L.R. (d) . 2938
 
 AMOUNTING.....................1
account, to be regarded as  amounting  only to a licence in law. The whole of the 696
 
 AMOUNTS.......................2
 amounts  of tax. The objective of horizontal equity is attained when two taxpayers in the same 1110
MTHL filed a GST rebate application in respect of  amounts  paid in error on January , 1228
 
 AMPLY.........................1
to a licence. That is by no means the only ground for the judge's decision. It is  amply  2080
 
 ANALOGOUS.....................1
 analogous  to that of a usufructuary. In particular, the right of enjoyment implies that the 1780
 
 ANALOGY.......................2
 analogy  was introduced in applying paragraph (f) of Part VI of Schedule V of the E.T.A. to 1952
The  analogy  between an interest in land in the common law and a real right in the civil law is far 1994
 
 ANALYSE.......................5
It is in this context that we are proposing to  analyse  the problems that arise in applying the 94
specifically in the E.T.A. We will then  analyse  the problems that exist in applying that concept in 104
The purpose of this section is not to thoroughly  analyse  the concept of lease in the common law 592
as a lease in the civil law? We will  analyse  these questions in the next section of our study. That 1554
at this point to  analyse  the contract of lease, an onerous contract closely related to loan for use.1920
 
 ANALYSING.....................2
will return to it in  analysing  licences in a Quebec civil law context. 176
As we stated when  analysing  the supply of mooring rights, the Department's view is that a 1240
 
 ANALYSIS......................16
creates a legal vacuum in this area in Quebec civil law, as we will see in our  analysis . Any 98
However, in Booker v. Palmer, an  analysis  of the parties' intention showed not only that 676
sometimes insufficient to decide the question, a more thorough  analysis  of the agreement in 758
bailment. While a thorough  analysis  is not necessary for the purposes of our study, suffice 872
Our  analysis  of licences has so far been limited to the field of property law in the common law. 892
What is relevant for the purposes of our  analysis  is that, according to the interpretation they 1150
(f) of Part VI of Schedule V in Quebec. An  analysis  of the circumstances surrounding the 1470
 analysis  will be important in seeking solutions for harmonizing paragraph (f) of Part VI of 1554
are almost exclusively contractual in nature, our comparative  analysis  of licences in the common 1716
in our  analysis  of the concept of licence in intellectual property, some comparisons 1734
with civil law leases. A detailed  analysis  of the contract and an examination of the parties' 2318
law context. Our  analysis  of the concept of licence in the common law has ultimately enabled us 2670
SHERMAN, D., David Shermans  Analysis  in GST Partner (CD-ROM) (Scarborough: 3056
D. Sherman, David Shermans  Analysis  in GST Partner (CD-ROM) 3424
administrative position and that an  analysis  of easements in the common law and servitudes in 3494
 analysis  is beyond the scope of our research. 3496
 
 ANALYZE.......................1
so much is conceded. In these circumstances it is unnecessary to  analyze  minutely the 746
 
 ANASTASIA.....................2
Canada in  Anastasia  Rubis v. Gray Rocks Inn Ltd. In that case, the Court had to 204
 Anastasia  Rubis v. Gray Rocks Inn Limited, S.C.R. . 2876
 
 ANGER.........................4
 ANGER , H.D. and J.D. HONSBERGER, Canadian Law of Real Property (Toronto: 2966
OOSTERHOFF, A.H. and W.B. RAYNER,  Anger  and Honsberger Law of Real Property, 3018
Sweet and Maxwell Limited, ), p. ; A.F. Oosterhoff and W.B. Rayner,  Anger  and 3172
Taken from A.F. Oosterhoff and W.B. Rayner,  Anger  and Honsberger Law of 3372
 
 ANGLOPHONE....................1
First of all, in so far as the E.T.A. applies to both  Anglophone  and Francophone taxpayers in 2686
 
 ANIMALS.......................1
Both specific restitution and monetary restitution were possible (often  animals  were used for 3184
 
 ANNEXED.......................2
A right  annexed  to land to utilize other land of different ownership in a particular manner 800
was no intention to create any rights  annexed  to land, or any interest in land. . . . At 840
 
 ANNUITIES.....................1
and of association, deposit, loan, suretyship,  annuities , insurance, gaming and wagering, 3544
 
 ANSTALT.......................3
Following these few fluctuations in the case law, the court in Ashburn  Anstalt  v. Arnold 578
 Anstalt  v. Arnold, a contractual licence in the common law is not enforceable against a 1858
Ashburn  Anstalt  v. Arnold, Ch. , All E.R. . 2878
 
 ANSWERS.......................1
form? What civil law institution is most similar to that concept? Finally, our  answers  will lead us 108

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