Black v. The Queen, 2014 DTC 1046 [at at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275 -- summary under Subsection 45(2)

By services, 28 November, 2015

In 2002, the taxpayer was resident both in Canada and the U.K. for domestic tax purposes, but by virtue of Art. 4, para. 2(a) of the Canada-U.K Income Tax Convention (the "Convention") he was a resident of the U.K. for purposes of the Convention. S. 250(5) of the Act, which otherwise might have explicitly deemed his non-residence under the Convention to apply for purposes of the Act, did not apply to him in 2002.

After noting a Crown submission that s. 250(5) effected a change to the Act, Rip CJ stated (in f.n. 33):

Subsections 45(2) and 44(f) of the Interpretation Act…provide that the repeal and the re‑enactment of a provision are not presumed to change the law. However, amendments, repeals and re‑enactments to the Act usually represent a change in the law due to the nature, object and context of the Act: see Century Services Inc. v. Canada (A.G.), [2010] 3 S.C.R. 379; 2010 SCC 60 at para. 54, per Deschamps J., at para. 129, and… Silicon Graphics Ltd. v. R., 2002 FCA 260 at para. 43.

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amendments usually change the Act
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