Pembina on the Red Development Corp. Ltd. v. Triman Industries Ltd., 92 DTC 6174, [1992] 1 CTC 133 (Man. C.A.) -- summary under Subsection 224(1.2)

By services, 28 November, 2015

In finding that the pre-1993 version of s. 224(1.2) of the Act was not ultra vires (before following Lloyds Bank), Scott C.J.M. stated (p. 6177):

"The purpose of the Act is not only to levy tax, but to collect it ... The machinery for collection and enforcement under the Act is part of the very subject matter of sec. 91(3) of the Constitution Act and not merely incidental to the raising of revenue".

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Income Tax Act - s. 224(1.2)
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