Carswell is making the Practitioner’s Income Tax Act (PITA) even more useful by switching to neutral citations for its case references. The neutral citation provides a sure-fire way to locate a case quickly and easily, regardless of the database you are using. I use Carswell’s online product anyway, but I usually prefer wrestling with the Act in its corporeal form, and so, even for a Carswell guy like me, neutral citations will facilitate finding cases.
The neutral citation is also more compact, which is pretty important to PITA’s editor as he tries to cram in more information about a statute that grows ever longer and more complicated every year. How much space could be saved? David Sherman reports that PITA likely contains about 7,500 case citations, and so the potential for saving space could be significant. For example, the reference to Guindon in the notes for 220(3.1) might change from “Guindon, [2013] 5 C.T.C. 1 (FCA), paras. 57-58 (aff’d without discussing this issue 2015 CarswellNat 3231 (SCC))”, which is 114 characters, to “Guindon, 2013 FCA 153, paras. 57-58 (aff’d without discussing this issue 2015 SCC 41)”, which is only 87 characters. (Query whether Carswell might try to save another four or five characters by using “¶ 57-58”, per the neutral citation standard, rather than “paras. 57-58”.)
Of course, the change won’t happen overnight. David estimates that if he converts 100 cases in each edition of PITA, it will take him 37 years to effect the conversion fully!
