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Maccabi Canada v. M.N.R.

A-587-96

Létourneau J.A.

30/6/98

7 pp.

Appeal from decision of Minister of National Revenue made under Income Tax Act, s. 168(1)(b) to revoke appellant's registration (Maccabi Canada) as registered Canadian amateur athletic association-Interpretation to be given to phrase "promotion of amateur athletics in Canada on a nation-wide basis" in definition of registered Canadian amateur athletic association (RCAAA) in Act, s. 110(8)(b)-Respondent finding registration erroneously granted to appellant in 1975 as latter excluded from ranks all Canadians not Jewish, of Jewish faith, therefore did not meet demographic requirement contained in words "nation-wide-basis"-Contents of Act, s. 168(1) dealing with revocation of registration of RCAAA not free from ambiguity-Words "nation-wide basis" describing geographic requirement only-Sufficient that Canadian amateur association applying for registration under Act carries on activities across Canada and not be provincially, regionally, locally limited-Interpretation consistent with legislative intent to ensure issuing of receipts to donators would come from single organization at national level-Words "nation-wide basis" not including demographic requirement not originally contemplated, intended by Parliament-Appeal allowed-Income Tax Act, S.C. 1970-71-72, c. 63, ss. 110(8)(b), 168(1).

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