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Statutory Interpretation - "Subordinate"

. Stackhouse v. Canada

In Stackhouse v. Canada (Fed CA, 2025) the Federal Court of Appeal dismissed a taxpayer's appeal, here from a Tax Court finding that the "amended farming loss restriction rule" applied to her situation. Where this rule applies then a taxpayer who "incurs a loss from carrying on a business" cannot "deduct it against their income from another business, property or employment".

Here the court considers the meaning of the term 'subordinate':
[81] "“Subordinate”" has several meanings. However, in the context of a comparison, its meanings include "“dependent upon, subservient to, or secondary to some other (chief or principal) thing”" and "“of lesser importance, not principal or predominant”": Oxford English Dictionary (online). While I consider these expressions to be substantially the same, I observe that "“not predominant”" is among them. In other words, "“subordinate”" can be seen as an antonym of "“predominant”".

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Last modified: 29-09-25
By: admin